The company Degli Esposti A. Srl (hereinafter referred to as the ‘DEA’ and/or the ‘Company’) conducts its activities in an ethical manner, with moral integrity and fairness, pursuing the statutory purposes in compliance with its corporate mission.

All persons linked to DEA, recipients of this Code, must demonstrate total moral integrity in the actions undertaken on behalf of the Company.

Transparency and moral integrity are understood as:

• Adherence to DEA’s institutional policies established in the Code of Ethics;
• Compliance with regional, state, European, or other country legislation when operating there;
• Transparent and direct communication with public bodies and with the various subjects with which DEA operates;
• Taking responsibility for one’s actions.

The Code of Ethics is the fundamental charter of moral rights and duties that defines the ethical and social responsibility of every component of our society.

1.1  NATURE OF THE CODE OF ETHICS

The Code of Ethics is aimed at all those who work for and with DEA, in order to make the ethical principles that inspire the Company clear, unequivocal and understandable.

The Code, in fact, is the official document in which the ethical principles in which DEA is reflected are set out and which, coherently, must inspire all the subjects with whom it operates. The purpose of this Code is to:

• Establish a standard fully aimed at preventing the commission of crimes related to the activity of DEA or in any case in the interest or advantage of the company;
• Identify measures and internal control tools suitable for monitoring compliance with the code itself;
• Create and increase business value.

1.2  OBJECTIVES OF THE CODE OF ETHICS

The needs analysed by this Code are not only legal and economic but are dictated by a precise social and moral commitment that DEA assumes.

The Company wants to be an example in adhering to the following legal and deontological principles for all Stakeholders:

• LEGALITY – TRANSPARENCY – FAIRNESS – RESPECT – ETHICS – SAFETY – TRACEABILITY – ACCOUNTABILITY: DEA operates legally and ensures that all parties obliged to comply with this Code comply with the laws and other regulations of the legal systems in force, preventing them from committing crimes and any other type of offence. DEA wants to avoid any conduct that may facilitate or lead to suspicion, even indirectly, of the commission of any type of offence, undermine the trust of stakeholders or transparency towards them or that may simply disturb the tranquility of the work environment.
• With regard to institutions, DEA wants: to work within the established rules and to make the nature of its purposes available and clear; Carry out their work while maintaining the utmost confidentiality; reconcile its goals with the needs of the community;
• Towards stakeholders, DEA wants: To inform about the transactions in which the Company is involved, which could influence their decisions; draw up the financial statements and all mandatory documents in a clear, transparent, truthful and correct manner; comply with all applicable laws, preventing its Directors from acting in conflict of interest with DEA and all stakeholders; have an ethical and respectful conduct towards all stakeholders, maintaining the utmost confidentiality of the information received in compliance with privacy and all the highest standards.

1.3 RECIPIENTS OF THE CODE OF ETHICS

The recipients of the Code of Ethics, obliged to observe the principles contained therein and subject to sanctions for violation of its provisions, are Shareholders, Directors as well as any person who exercises the management and control of DEA regardless of their legal or formal qualification.

All employees and collaborators, including occasional ones, of DEA are also obliged recipients of the Code of Ethics and subject to sanctions for violation of its provisions.

The Code is also intended to include consultants, suppliers, partners in the Company’s commercial initiatives and anyone who carries out activities in the name and on behalf of DEA or under its control, and stakeholders.

The code of ethics is therefore aimed at:

– all employees, regardless of role or hierarchical level

– external collaborators, consultants, agents

– business partners and suppliers, within the limits of contractual relationships

– all the Company’s operating offices

Each recipient is expressly obliged to know its content and to contribute to its application.

This Code of Ethics is available on the company home page (www.degliesposti.it).

2. THE COMPANY AND OUR PURPOSE

Founded on February 12, 1912, DEA represents Italian excellence in the detail of manufacturing for display materials of major luxury brands. In more than 100 years of development, from a heritage of craftsmanship linked to local tradition, the company has also become a leader in the world market, especially in Europe and Asia.

The constant innovation of the technologies and methodologies used allows a competitive and cutting-edge positioning in the various areas of ‘tailor-made’ production. The dense network of national and international suppliers, educated for several years on the required quality levels and periodically checked, allow the company to be responsive and productive capacity while maintaining high quality standards and in an increasingly sustainable direction.

3. RELEVANT VALUES AND CRITERIA OF CONDUCT

The fundamental values underlying the strategic choices and guiding DEA’s operational behaviour are actively promoted to all stakeholders.

DEA’s corporate culture is inspired by the core values that follow.

–     LEGALITY AND REGULATORY COMPLIANCE: The company is committed to complying with all current national and international regulations applicable to its activities.

–     INTEGRITY, TRANSPARENCY AND FAIRNESS – ANTI-CORRUPTION – ANTI-BRIBERY – ANTI-MONEY LAUNDERING: DEA behaves in a manner based on moral integrity, transparency and conforms to the highest ethical standards, extending these values to anyone who comes into contact with the Company; DEA rejects any form of corruption and deceptive behavior, abuse of power or conflict of interest.

DEA is inspired, among others, by the principle of transparency and completeness of information in the performance of institutional activities, in the management of the financial resources used and in the consequent reporting and/or accounting recording. The Company is inspired by the principle of transparency and completeness of information in the preparation of all documents.

–     SOCIAL RESPONSIBILITY – PROTECTION OF HUMAN RIGHTS – HEALTH AND SAFETY: DEA is committed to ensuring decent working conditions, high standards of health and safety, equal opportunities, inclusion, non-discrimination, respect for diversity, prohibition of child or forced labour, child protection, protection of trade union rights and related associations, working hours and remuneration. It is also committed to promoting social, economic and/or employment development in compliance with internationally recognized standards and rights in the field of protection of fundamental rights and non-discrimination.

–     ENVIRONMENTAL PROTECTION AND SUSTAINABLE DEVELOPMENT: DEA promotes, with a view to social and corporate responsibility, the utmost attention to sustainability. In this direction, it has undertaken a training and certification process and has already obtained a positive result in the Ecovadis questionnaire. The company’s goal is to focus on the maximum reduction of environmental impacts, the prevention of pollution, a responsible use of resources, waste management and renewable energy.

–     ETHICAL RELATIONSHIPS IN THE SUPPLY CHAIN: DEA’s suppliers are required to adhere to ethical, social and environmental standards, and commitment to monitoring the supply chain.

–     CONFIDENTIALITY, DATA PROTECTION AND CYBERSECURITY: Dea guarantees the maximum protection of company, customer and partner information, according to current regulations (e.g. GDPR).

–     CULTURE OF QUALITY – CONTINUOUS IMPROVEMENT – TRACEABILITY AND INNOVATION: Our experience aims to seek effective, future-oriented solutions, with traceable data and aimed at continuous improvement, without sacrificing the quality that distinguishes our work.

–     The Company upholds the following international principles and standards, committing itself to progressively integrating them into its internal policies, processes and business relationships:

• United Nations Universal Declaration of Human Rights
• Fundamental conventions of the International Labour Organization (ILO)
• United Nations Guiding Principles on Business and Human Rights (UNGPs)
• OECD Guidelines for Multinational Enterprises
• The Ten Principles of the United Nations Global Compact (Human Rights, Labour, Environment, Ethics)
• ISO 26000 – Social Responsibility Guidelines

3.1  LEGALITY AND REGULATORY COMPLIANCE:

3.1.1 CORPORATE COMMUNICATIONS AND ACCOUNTING RECORDS

DEA believes that regulatory compliance 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 efficient 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, DEA reiterates that the financial statements must represent the economic, equity or financial situation of the company in a true, clear and complete manner.

3.1.2 OTHER OBLIGATIONS IN RELATION TO ADMINISTRATION

DEA’s corporate assets are managed correctly and honestly and, therefore, all those obliged to comply with this Code contribute to protecting their integrity so that they are fully safeguarded to protect creditors, investors, etc.

In light of the above:

• The company’s assets, assets, receivables must be valued correctly, not attributing to them values higher than those due;
• Transactions on the share capital, or other types of transactions, may not be carried out through the use of non-distributable profits or reserves required by law;
• The share capital cannot be reduced except in the presence of losses or write-downs;
• The Directors may not purchase or subscribe to shares or quotas, except through their own resources;
• The statutory purposes must be pursued;
• The management of the company’s assets must be consistent with the nature of DEA, which operates according to principles of transparency and morality;

The same principles must be used in valuations and in any other extraordinary transactions (mergers, demergers, etc.).

3.2 INTEGRITY, TRANSPARENCY AND FAIRNESS – ANTI-CORRUPTION – ANTI-BRIBERY – ANTI-MONEY LAUNDERING

3.2.1 RELATIONS WITH THE PUBLIC ADMINISTRATION

Even in the performance of negotiations and any other activity towards the Public Administration, DEA behaves correctly and transparently.

DEA’s relations with public officials (including public employees – regardless of whether they are in charge of public service or not – and public service concessionaires) are based on transparency, loyalty and fairness: DEA does not want to create the slightest suspicion of wanting to unduly influence these subjects to obtain benefits by illegal means.

DEA condemns, in fact, any behavior that may constitute an act of corruption. Similarly, employees and collaborators must report to their manager any attempt at extortion or bribery by a public official of which they may be the recipients or aware.

In light of the above, no employee and collaborator of DEA, by way of example, may:

• Give or promise gifts, money, or other benefits to such individuals in a manner that influences the impartiality of their personal judgment; notwithstanding the above, donations of modest value and courtesy gifts are allowed within the limits of use and custom and provided that they are such as not to compromise the image of the company;
• Send false or artfully formulated documents, attest to non-existent requirements or guarantees that do not correspond to the truth;
• Unduly procure any other type of profit (licenses, authorizations, reductions in charges, including social security, etc.) by means that constitute artifice or deception (for example: the sending of false documents or attesting to untrue things);
• Undertake economic activities, confer professional assignments, make or promise gifts, money, or other advantages, to public officials or public employees involved in administrative proceedings that may result in advantages for DEA;
• Alter in any way the operation of an IT or telematic system of the Public Administration or third parties or intervene without right in any way on data, information or programs contained in one of the aforementioned systems;
• Unduly receive contributions, loans, subsidized loans or other disbursements of the same type in any way denominated, granted or disbursed by the Public Administration, through the use or publication of false or misleading documents, or through the omission of due information;
• Use contributions, subsidies or funding intended for the construction of public works or the performance of activities of public interest, for purposes other than those for which they are granted;
• Unlawfully exchange information on bids with participants in any tenders or public procedures.

It is a violation of DEA’s institutional policy to adopt conduct that constitutes the crime of corruption, bribery and undue perception even in foreign countries where such conduct is not punished or otherwise prohibited.

Finally, to avoid giving or receiving undue payments, employees and collaborators, in all their negotiations, must comply with the following principles regarding the documentation and keeping of records:

• All payments and other currency transfers made by or to DEA must be accurately and fully recorded in the books and mandatory records;
• All payments must be made only to the recipients and for activities contractually formalized and/or approved by the DEA;
• No false, incomplete or misleading records must be created and no hidden or unrecorded funds must be established and funds may not be deposited in personal or non-DEA accounts;
• No unauthorized use of DEA’s funds or resources shall be made.

3.2.2        JUDICIAL AUTHORITIES AND SUPERVISORY AUTHORITIES

DEA acts in compliance with the law and promotes, within the limits of its competences, the correct administration of justice.

In carrying out its activities, DEA operates lawfully and correctly, collaborating with the judicial authorities, the police and any public official who has inspection powers and carries out investigations against it.

DEA reiterates, in fact, that it condemns any behavior that may constitute an act of corruption. Employees and collaborators must report to their manager any attempt at extortion or bribery by a public official or a public service officer of which they may be recipients or aware.

DEA requires that all employees or collaborators lend the utmost availability and collaboration to public officials or Supervisory Authorities who come to carry out inspections and controls on the company’s work.

In anticipation of a judicial proceeding, investigation or inspection by the Public Administration or Supervisory Authorities, no one must destroy or alter records, minutes, accounting records and any type of document, lie or make false statements to the competent authorities.

No one should attempt to persuade others to provide false or misleading information to the relevant authorities.

No one may engage in economic activities, confer professional assignments, give or promise gifts, money, or other advantages to those who carry out the checks and inspections, or to the competent authorities.

All public contributions received must be used for the purposes prescribed by the calls themselves without illegal or ulterior use.

3.2.3. CONFLICT OF INTEREST

The Company adopts ethical behavior in all business relationships, committing itself to:

• Preventing corruption, bribery, extortion and fraudulent practices
• avoid conflicts of interest
• prohibit gifts or giveaways that may influence professional decisions
• ensure transparency and fairness in communications
• comply with the legislation on the protection of personal data (GDPR)

DEA ensures that its employees, directors, representatives or collaborators do not find themselves in a condition of conflict of interest, every operation and activity must be undertaken solely and exclusively in the interest of the company and in a lawful, transparent and correct manner.

All choices and actions taken by DEA’s employees and collaborators must be oriented towards the best possible advantage for DEA and the pursuit of social development. DEA, therefore, establishes the following rules:

• The Directors may not carry out or collaborate in transactions (or participate in the related resolutions) in which they have a competing interest, even partially, with that of the Company;
• DEA’s employees and collaborators may not carry out business or other professional activities in competition with DEA’s interests and with the purposes pursued by it, indicated in the bylaws and referred to in this Code.

DEA’s employees and collaborators may not participate or collaborate in any way in any transaction, financial operation or investment made by the Company from which they may derive a profit or other type of personal advantage not provided for in the contract, except in the case of express authorization from DEA itself.

It is the duty of all DEA employees, collaborators and directors to avoid and prevent the emergence of a conflict of interest.

Every employee and collaborator in charge of carrying out negotiations with private individuals on behalf of DEA must inform where there is a possibility that a conflict of interest may arise.

In order to comply with the principle of fairness and transparency, as well as to ensure the trust of the community and the beneficiaries of its interventions, DEA ensures that all the obligated recipients of this Code do not find themselves in a situation of conflict of interest.

3.2.4        INSIDE INFORMATION

All information obtained from DEA’s employees and collaborators in relation to their employment and collaboration relationship is the property of the Company.

DEA respects the principles of loyalty, fairness, equal access to information and transparency, in full compliance with the law.

Therefore, if DEA is the holder of inside information due to its partnership relationships, it undertakes to maintain the utmost confidentiality.

Inside information is specific information, which is not available to the public, concerning customers, projects, company know-how, suppliers, financial instruments or issuers of the same, whether listed or not, which, if made public, is likely to influence the financial performance of the parties involved.

The prohibitions are also extended to family members, cohabitants, collaborators and anyone who, due to their confidential relationship with the subjects exposed above, comes into possession of such information.

3.2.5 COMMERCIAL, PROCUREMENT AND MARKETING ACTIVITIES – ANTI-CORRUPTION – ANTI-BRIBERY AND ANTI-MONEY LAUNDERING

Any employee or collaborator who works in the context of a commercial activity is invited to submit to the Management any doubt or initiative that may fall within the legal sanctions provided for in order to operate in full compliance with the rules. The customer is the fulcrum of the company’s activity; Employees and external collaborators are therefore required to constantly strive to guarantee the best quality standards that are part of our excellence

All business relationships are inspired by the principles of loyalty, lawfulness and transparency, aimed at maximum fairness in business and in relations with customers. It is not permitted to offer gifts or money to officers, employees, managers, directors, partners or their relatives. Each expense incurred must be authorized and documented, identified in the accounts and properly treated for tax purposes according to the internal controls provided. Employees who receive gifts or donations from third parties must be brought to the attention of the Management.

 For the supply of goods and/or services, it is essential to observe any internal procedures envisaged for the selection and management of relations with suppliers, including in terms of sustainability; ensure maximum customer satisfaction in terms of quality, cost and delivery times; observe the contractual conditions and good commercial practices with suppliers, bringing Management and Superiors to the attention of problems that have arisen.

In marketing campaigns, Dea undertakes to provide information that is consistent with its reality together with the protection of privacy regarding news and information relating to the data managed.

Dea does not tolerate any form of corrupt practice, such as, but not limited to, fraud, extortion, or bribery.

The Company strives to prohibit corruption in all domestic and international business transactions through the principles set out above that may compromise the fair management of business decisions.

The company condemns any action aimed at money laundering or terrorist financing that may be promoted directly or indirectly.

3.3 SOCIAL RESPONSIBILITY – PROTECTION OF HUMAN RIGHTS – HEALTH AND SAFETY

3.3.1 PROTECTION OF HUMAN RIGHTS

DEA is committed to creating a serene working environment within it in which everyone can work in compliance with the laws, principles and fundamental rights of each individual, protecting moral integrity and ensuring equal opportunities. The Company recognizes and protects Human Rights, committing itself to:

• prevent any form of discrimination based on gender, age, ethnicity, religion, sexual orientation, disability, personal opinions or other personal characteristics
• ensure dignified, safe and person-friendly working conditions
• Ensuring freedom of expression and respect for privacy
• protect the rights of the communities affected by the company’s activities

In order to achieve continuous improvement in this area, the Company promotes the following principles:

Trust: DEA believes that effective relationships, both internally and externally, can only be established if deep trust is established between the parties.

Sharing: DEA seeks to play its full role in stimulating the sharing of information, knowledge, experience and professional skills both within the Company and, where appropriate, externally.

Group Work: Teamwork and a sense of common goals pervade all the company’s activities due to the awareness and conviction that DEA’s success depends on teamwork between managers and staff, which is capable of creating new value.

Collaboration is a core value of society and is considered an added value; all company members must have it.

Responsibility towards the community: DEA, in carrying out its activities, assumes its responsibilities towards the community, inspired by the values of solidarity and dialogue with interested parties. The Company maintains and develops a relationship of trust and a continuous dialogue with stakeholders, trying, where possible, to inform and involve them in the issues that concern them.

Value of Human Resources and Equal Opportunities: Our people are the key to business success. According to this principle, Dea promotes improvement, recognition of results achieved and professional potential. The Company also pays particular attention to innovation, sustainability and equal opportunities activities within the Company.

Any form of physical, psychological, economic or verbal abuse is prohibited.

DEA ensures the confidentiality of information (also) with regard to employees and collaborators.

DEA ensures that its employees and collaborators behave and are treated with dignity and respect, within the framework of the provisions of the laws of our legal system and their amendments. DEA does not tolerate any form of isolation, exploitation or harassment for any reason of discrimination, for personal or work reasons, by any employee or collaborator towards another employee or collaborator.

DEA also prohibits any disciplinary sanction against employees or collaborators who have legitimately refused to perform work unduly requested of them by any person linked to the Company.

Sexual harassment of any kind will be severely punished, as provided for both by the disciplinary system of the CCNL of reference and by the disciplinary system of the Organization and Management Model pursuant to Legislative Decree 231/01 also with the termination of the employment and collaboration relationship.

DEA is opposed to any type of discrimination based on diversity of race, language, color, faith and religion, opinion and political affiliation, nationality, ethnicity, age, sex and sexual orientation, marital status, disability and physical appearance, economic and social condition as well as the granting of any privilege related to the same reasons.

DEA is against “undeclared work”, obliged, child and child as well as any other conduct that integrates the offences against the individual personality;  it also condemns all forms of forced labour, imprisonment, slavery and human trafficking. Every employment and collaboration relationship is established with a regular contract. All employees and collaborators are correctly and fully informed of the rights, duties and obligations arising from the conclusion of the contract. DEA recognizes and promotes trade union rights in compliance with current laws.

Selection, training and professional development follow the criteria of equal opportunities and non-discrimination, according to criteria of merit, skills and professionalism.

The same behavior is also expected with regard to those who hold top positions in the company

3.3.2        HEALTH AND SAFETY

DEA is also committed to the utmost compliance with workplace safety regulations and to promoting safety in all places that make up the work environment itself, even beyond the express legal obligations. In particular, it considers it essential to provide safe and healthy working conditions to employees, suppliers and contractors on site, in accordance with the laws in force on the subject, ensuring that everyone is aware of the roles held and the actions to be taken, providing adequate training and drafting appropriate procedures pursuant to and for the purposes of Legislative Decree 81/2008. Dea recognises health and safety at work as fundamental human rights and is committed to ensuring a healthy, safe working environment that respects the dignity of the person. This commitment is based on the principles of key international regulations and guidelines, including International Labour Organization (ILO) Conventions, OECD Guidelines on Responsible Business Conduct and globally recognised management standards. The Company promotes a culture of prevention based on:

• Identifying, assessing and mitigating health and safety risks, including along the value chain.
• Implementation of operating systems and procedures that follow the highest international standards
• Periodic review of prevention measures, with objectives of continuous improvement and active involvement of staff.

The Company promotes an environment open to collaboration and dialogue, in which every worker can report dangerous situations, risky behavior or non-compliance, without fear of retaliation.

Dea promotes the active involvement of staff and structured process management. The Company has clear procedures for managing emergencies, which include:

• periodic evacuation plans and simulations;
• correct use of personal protective equipment;
• fast and effective communication systems.

3.4 ENVIRONMENTAL PROTECTION AND SUSTAINABLE DEVELOPMENT

3.4.1 ENVIRONMENTAL PROTECTION

The Company is also committed to conducting its business in an environmentally responsible and sustainable way, to ensure maximum compliance with current laws while reducing environmental impact as much as possible. Suppliers must conduct their business responsibly and environmentally friendly by  ensuring that their operations comply with legal requirements and by committing to continuous improvement to minimize environmental impact.

It is therefore essential to conduct one’s business by guaranteeing emissions into the atmosphere according to legal requirements and practicing good water management, minimizing consumption.

In this direction, it has embarked on an environmental certification process by obtaining the ISO 14001:2015 Certification and obtaining a positive result in the Ecovadis questionnaire.

3.4.2 SUSTAINABILITY DEVELOPMENT

Dea recognizes sustainability as a strategic value and a fundamental ethical principle, committing itself to integrating environmental, social and economic considerations into all its activities. In line with international standards, the organization promotes responsible conduct oriented towards continuous improvement and the creation of shared value through:

environmental sustainability: The company is committed to reducing the environmental impact of its operations by adopting practices aimed at protecting the ecosystem and fighting climate change, promoting energy efficiency and the use of renewable sources and reducing waste production.  Dea also adopts environmental criteria in the selection of suppliers and partners, promoting sustainable mobility and the adoption of low-impact technologies;

social sustainability: Dea places respect for human rights, the enhancement of people and the promotion of a fair, safe and inclusive work environment at the centre of its policies, guaranteeing equal opportunities and combating all forms of discrimination, promoting the health, safety and well-being of workers, investing in training and professional development,  encouraging social initiatives;

Ethics in purchasing and in the supply chain: The company requires its suppliers and business partners to comply with ethical and sustainable principles, in line with the following values: Assesses suppliers on the basis of environmental, social and ethical parameters – Promotes transparent and responsible business relationships. Promotes traceability and regulatory compliance along the value chain;

Economic sustainability and Responsible Governance: Dea pursues economic objectives in an ethical and sustainable way, adopting transparent and responsible governance practices. In particular: It integrates ESG criteria into decision-making processes, promotes sustainable innovation and efficient management of resources, ensures transparency in communication with stakeholders;

monitoring, evaluation and continuous improvement: The Company is committed to regularly monitoring and evaluating its sustainability performance using measurable indicators and reporting tools, in particular it promotes continuous improvement through audits, training and staff involvement, transparently communicating results and objectives.

3.5 ETHICAL RELATIONSHIPS IN THE SUPPLY CHAIN

3.5.1 RELATIONSHIPS WITH BUSINESS PARTNERS AND SUPPLIERS

Dea carries out a careful selection of business partners and suppliers of products and/or services (collectively considered the “suppliers”); this must be carried out in accordance with the principles of this Code and any internal procedures adopted from time to time. Relations with suppliers are based on compliance with current legislation and must be managed in application of the general principles of transparency and fairness, proceeding with the contractualization of the economic relationship. In its relations with suppliers, the Company operates with criteria of loyalty, fairness and impartiality. The commercial agreements entered into with suppliers are based on pre-contractual and contractual conduct and are based on the principle of loyalty, collaboration and transparency. Each supplier must comply with the applicable laws, regulations and/or standards in the country in which it operates or is located. In particular, every supplier who comes into contact with the Company undertakes to ensure compliance with the policies relating to the working environment, integrity, ethics and anti-corruption, operating in accordance with the principles set out in our Code of Ethics. The undersigned company has the right to subject suppliers to periodic audits, including through supplier self-assessment questionnaires, to verify the adoption and maintenance of the required standards.

The Company requires suppliers and business partners to comply with principles equivalent to those contained in this Policy, committing themselves to:

• assess ESG risks in the supply chain
• include contractual clauses on ethics, human rights and working conditions
• Promote continuous improvements through dialogue, audits or evaluation questionnaires

3.6 PRIVACY AND DATA PROTECTIONS-CYBERSECURITY 

3.6.1 CONFIDENTIALITY AND DATA PROTECTION

To safeguard its communication and public relations policy, its image and the correctness of the information released, DEA requires that:

• No employee and/or collaborator issues any type of declaration with information regarding DEA to unqualified external parties not authorized by the manager;
• Any employee and/or collaborator who is solicited by unqualified external parties to issue statements or information regarding DEA and whose release may result in damage, refers the applicants to the relevant bodies;
• No employee and/or collaborator, unless authorized, spends the name of DEA or its President in any way towards third parties in order to procure advantages for themselves or others.
• All collaborators are therefore required to maintain the strictest confidentiality on all information relating to the Company and/or its employees and/or customers and/or business partners.

3.6.2 USE OF IT TOOLS AND CYBERSECURITY

All recipients who carry out activities in the interest of the Company (or who promote its services and/or products), in carrying out the related activities, must undertake to use the IT or telematic tools and services in compliance with the regulations in force on the subject (IT security, privacy, IT offences, etc.), as well as all the Company‘s internal company procedures. Employees and/or persons who use the IT tools made available to the Company undertake to use them exclusively for business purposes in accordance with the required legal standards. The Company expressly prohibits any conduct that alters the operation of computer systems and/or manipulates the data contained therein, as provided for in the IT Policy. All recipients are required to contribute to the maintenance of an optimal standard of corporate cybersecurity by promptly reporting any critical issues to the head of the IT department or to the equivalent cybersecurity function of the Company.

3.7 CULTURE OF QUALITY – CONTINUOUS IMPROVEMENT – TRACEABILITY AND INNOVATION 

The Company promotes a culture of quality oriented towards customer satisfaction, error prevention and compliance with applicable technical and regulatory standards. Each employee is responsible for his or her own contribution to the quality of products, services and business processes.

DEA also adopts the principle of continuous improvement, encouraging the reporting of any critical issues, the sharing of ideas and the identification of solutions that can promote operational efficiency, safety and sustainability.

All activities must be carried out according to clear and up-to-date procedures, in compliance with company management systems and improvement objectives.

The company strives to ensure the traceability of processes, materials and information, ensuring that each production and administrative phase is documented in an accurate, transparent and verifiable manner. The manipulation, recording and storage of data must be carried out precisely, correctly and in compliance with current regulations on the quality and security of information.

Dea also supports the search for innovative solutions, promoting the adoption of technologies, tools and methodologies that can improve the competitiveness, reliability and sustainability of its products and processes. All stakeholders are invited to actively participate in the change, adopting an open, proactive and future-oriented approach.

4. DISSEMINATION OF THE CODE OF ETHICS

This Code of Ethics is communicated to all employees, collaborators and partners, and made publicly available on the company website www.degliesposti.it

5. VERIFICATION AND SANCTIONING SYSTEM FOR EMPLOYEES AND DIRECTORS – COLLABORATORS, SUPPLIERS, CONSULTANTS AND COMMERCIAL PARTNERS

Failure to comply with and/or violation of the rules of conduct indicated by the Code of Ethics by employees and Directors of DEA constitutes a breach of the obligations arising from the employment relationship and gives rise to the application of disciplinary sanctions.

The sanctions will be applied in compliance with the provisions of the law and collective bargaining and will be proportionate to the gravity and nature of the facts.

The ascertainment of the aforementioned infringements, the management of disciplinary proceedings and the dispensing of sanctions remain the responsibility of the company functions in charge and delegated to do so.

Any conduct carried out by collaborators, suppliers, consultants and business partners connected to DEA by a non-employee contractual relationship, in violation of the provisions of this Code, may also determine, in the most serious cases, the termination of the contractual relationship, without prejudice to any claim for compensation if such conduct results in damage to the Company.

In the event that the Company ascertains that the third party does not fully comply with the principles of this Code of Ethics, adopting measures that partially comply with the provisions and/or there is a suspicion that the third party may engage in conduct contrary to the principles of the Code, the Company will communicate the circumstance to the third party, inviting the same to take all the necessary measures to comply with the provisions of the Code within a certain period of time. principles expressed therein.

5.1 WHISTLEBLOWING REPORTS

The company provides secure and confidential channels to report unethical behavior or violations of the Code of Ethics. No form of retaliation is tolerated against those who report in good faith. The company encourages the reporting of unethical behavior through dedicated channels, which guarantee confidentiality and protection from retaliation.

6. REVIEW

The Company undertakes to review the code of ethics periodically, at least every two years, to ensure alignment with the best practices and the highest international standards.