1.1 Introduction

The Code of Ethics adopted by Eurotrol S.p.A. is a set of principles and rules whose observance is of fundamental importance for the proper functioning and improvement of Eurotrol S.p.A.’s reliability. The code of ethics aims to clarify the ethical and social responsibilities of Eurotrol S.p.A. towards the various internal and external stakeholders, such as: employees, collaborators, suppliers, customers, etc..

The primary objective of the adoption of this Code is therefore to satisfy, in the best possible way, the needs and expectations of Eurotrol S.p.A.’s stakeholders, aiming to recommend and promote a high level of professionalism and to prohibit those behaviours that are in contrast not only with the regulatory provisions relevant from time to time, but also with the values that Eurotrol S.p.A. intends to promote. 

The individual and collective behaviour of Eurotrol S.p.A.’s employees and collaborators must therefore be in tune with company policies and must concretely translate into cooperation, seriousness, social responsibility and respect for the regulations in force, following the standards of behaviour identified by the Code of Ethics. 

The Code of Conduct is an essential tool with which Eurotrol S.p.A. intends to give directives and suggestions so that all its personnel operate in accordance with an ethical behaviour that is embodied in the following intentions: 

– strictly comply with the laws in force in the country; 

– to act with fairness and courtesy in relations between colleagues by providing all useful cooperation;

– respect the interests of all other stakeholders (customers, suppliers, institutions, public authorities);

– perform their role with professionalism and moral integrity with respect for human dignity.

The code also defines the procedures for verifying effective compliance with the operating procedures and the sanctions provided for in the event of violation of the “Code of Ethics” by personnel. This Code also contains the ethical principles relevant to the prevention of offences and compliance with the provisions of Legislative Decree no.  231/2001 and its subsequent amendments and/or additions.

1.2 Guiding principles

To achieve its corporate mission, Eurotrol S.p.A.’s way of operating is inspired by the general principles of sustainability and corporate responsibility, and its business mission is guided by the following values:

Impartiality: commitment to ensure that no prejudice to impartiality in the conduct of company business exists, or is minimised;

Pursuit of excellence: continuous pursuit of improvement in the way we operate, ensuring the highest level of competence and the latest updates in the performance of company activities with constant attention to detail at every stage of the work, using the resources in the most efficient way.

Development of People: attention and commitment with respect to the professional and managerial development of the People who work within the company, motivating and recognising everyone’s contribution in line with the organisational code of conduct.

1.3 Persons to whom the Code of Ethics applies

The rules of the Code apply, without exception, to all members of Eurotrol S.p.A., from the Employer to the Director, managers, collaborators, consultants and all company personnel; any other third party who may act on behalf of or upon appointment by the company must also ensure compliance with the Code. All the aforementioned subjects are required to learn and comply with its contents. 

2. Conflict of interest

In carrying out their work, each employee is required to avoid any possible conflict of interest, with particular reference to personal and/or family interests that could influence the independence of their judgement and enter into conflict with their responsibilities. Each employee shall immediately report to his/her hierarchical superior and/or the top management of Eurotrol S.p.A. any situation that constitutes or may generate a conflict of interest. 

3. Accuracy and transparency of accounting records

Eurotrol S.p.A. operates with the utmost transparency at administrative and accounting level, guaranteeing the truthfulness, accuracy and completeness of the information relating to each accounting entry. In order to prevent the inappropriate use of company funds or the recording of fictitious transactions, adequate supporting documentation for the activity carried out is kept for each operation, such as to allow the performance of checks to ascertain the characteristics and motivations of the operation and to identify who authorised, carried out, recorded and verified the same. Each employee is required to scrupulously observe all current administrative and accounting procedures. Eurotrol S.p.A. ensures the timely preparation of periodic financial statements, ensuring that they are complete, accurate, reliable and understandable.

4. Protection of company assets

Eurotrol S.p.A. defends and protects the company’s assets, also using tools to prevent misappropriation, theft and fraud against the company. 

Each employee is required to work diligently to protect the company’s assets, using the tools entrusted to him/her in a correct and responsible manner and avoiding improper use that is not pertinent to strictly work-related purposes; each employee must comply with the company’s instructions on the use of uniforms and work clothes provided by the company.  

Each employee must work diligently, aiming to attain the highest standards for the care and maintenance of work tools of any kind, which must be used in a careful and responsible manner, avoiding uses other than those permitted. In particular, then, with reference to the use of IT tools, each employee is required to scrupulously comply with the provisions of the specific document « Company Policy on the Use of Communication Tools« , introduced in compliance with the mandatory regulations on the processing of personal data.

Similarly, with regard to company cars, the employees who have one must strictly follow the instructions provided by the company and use it appropriately and in compliance with the law, for company purposes and not for unauthorised personal use. 

5. Protection of information and intellectual property

Company information of any kind (commercial, financial, technological, etc..) is an asset that Eurotrol S.p.A. aims to protect, as a heritage of culture and continuous technological investment. It is therefore forbidden to disclose to unauthorised persons (inside and/or outside the company) information that could jeopardise the professional business assets acquired over time. 

6. Duty of confidentiality and compliance with privacy legislation

Eurotrol S.p.A. ensures the protection of the information and personal data relating to its Employees and Third Parties and avoids their misuse, limiting data access to Employees who need such information/data for organisational and business purposes, in compliance with the applicable laws and best practice requirements for privacy protection. Eurotrol S.p.A. has implemented an adequate structure in order to be perfectly respectful of and compliant with the Privacy legislation, in full compliance with the GDPR European Regulation No.  679/2016 and Legislative Decree  196/2003 as amended by Legislative Decree  101/2018, adopting adequate rules for the processing of the personal data within its facilities and for their storage and preservation, in accordance with the preventive security measures in order to prevent their unlawful use, destruction, loss, unauthorised access or processing.

7. Protection of moral and physical integrity

All company personnel, whose physical and moral integrity is considered a primary value of Eurotrol S.p.A., are guaranteed working conditions that respect individual dignity, in safe and healthy working environments. 

In particular, Eurotrol S.p.A. does not tolerate:  

– abuse of power: it constitutes abuse of the position of authority to request personal services and favours as a due act of the hierarchical superior, or to adopt attitudes and/or perform actions that are detrimental to human dignity and especially to the autonomy of the employee; 

– acts of psychological violence: attitudes or behaviour that are discriminatory or harmful to the person and his or her beliefs; 

– sexual harassment, behaviour or speech that may disturb the personal sensitivity of the worker; 

– acts of bullying, which may also seriously affect the health of the worker on the work site; 

– operational bullying, which can lead to psychological situations with serious consequences in the employee’s operational activity. 

8. Suppliers

Eurotrol S.p.A. considers its suppliers as valuable business partners and key contributors to the achievement of corporate objectives. Business relationships must be managed taking into account the principles and values indicated in the previous paragraphs. Suppliers shall observe and respect the values and principles expressed in this Code and in all the Eurotrol S.p.A. relative documentation. Eurotrol S.p.A.’s approach and behaviour during the selection and qualification phases and for the entire duration of the supply of goods and services must be based on excellent levels of quality and service, product and process innovation and cost competitiveness. Eurotrol is committed to guaranteeing fair opportunities to any potential supplier, in compliance with the principles of transparency, in order to develop cooperative and collaborative relationships through a constant and interactive communication process for mutual partnership. Eurotrol promotes the creation of common and shared values and business objectives, avoiding possible situations of dependence and abuse of position, both for the Company and for suppliers. The suppliers must be selected based on the assessment of the quality of services and products as well as their competitiveness, as well as on the congruence of performance, professional and technical to specifications, but also to social and environmental responsibility.

9. Gifts, presents and benefits

It is not permitted to offer and receive or promise forms of gifts or benefits that may be interpreted as exceeding normal courtesy practices, or that may be intended as a means of acquiring favourable treatments during the performance of the work activities. Any type of corruptive behaviour towards public officials, officers or employees of the Public Administration, public authorities and institutions, in any form or manner, is not tolerated. The rules regulating this matter in the individual national legislations must be strictly observed. The aforementioned rules may not be circumvented by recourse to third parties. Gifts also include benefits such as, for example, offers to attend training courses or promises of employment. 

10.1 Compliance with the Code of Ethics and Conduct

Compliance with the rules of this Code must be considered an essential part of the contractual obligations of employees and all recipients to whom it applies. It must also be considered an essential part of the contractual obligations undertaken by the collaborators, including subordinates and/or parties that have business relations with the company. Eurotrol S.p.A. is responsible for ensuring that its expectations of conduct towards recipients are understood and implemented by them.

10.2 Whistleblowing Policy (Annex A) 

In order to ensure the effective application of the ethical principles contained in this Code and the prevention of the predicate offences referred to in Legislative Decree  231/2001, Eurotrol S.p.A. requests that all those who become aware of situations which constitute a violation of ethical principles, or which could constitute the commission of one of the predicate offences referred to in the Decree, make a report. The reports, which shall be kept strictly confidential by the Supervisory Body, shall be made in accordance with the prescriptions of the Whistleblowing Policy that is annex A to this Code of Ethics. EUROTROL S.p.A. guarantees that persons who make a report within the indicated terms will not be subject to any negative consequences and the report made will be kept confidential. 

10.3 Sanctions

Violation of the principles laid down in the Code of Ethics and Conduct and in the Eurotrol S.p.A. procedures compromises the relationship of trust between Eurotrol S.p.A. and whoever commits the violation (directors, board of auditors, collaborators, consultants, company personnel, customers, suppliers). Violations, once ascertained, will be prosecuted, with promptness and immediacy, through the adoption, in accordance with the provisions of the regulatory framework in force, of appropriate and proportionate disciplinary measures, regardless of the possible criminal relevance of such conduct and the institution of criminal proceedings in cases where they constitute a crime. 

In the case of violations by suppliers and collaborators, penalties will be applied and in the most serious cases termination of the relationship, under the terms provided for in the contracts. In the case of violations by employees, disciplinary measures for violations of this Code shall be taken by Eurotrol S.p.A. in line with the laws in force and the relevant national employment contracts applied to the employment relationship existing with Eurotrol S.p.A., in particular with the disciplinary code adopted by Eurotrol S.p.A. and delivered to employees as well as displayed on the notice board. Such measures may also include the removal from Eurotrol S.p.A. of those responsible for such misconduct. 

Eurotrol S.p.A., in order to protect its image and to safeguard its resources, will not entertain relationships of any kind with individuals who do not intend to operate in strict compliance with current regulations, and/or who refuse to behave in accordance with the values and principles set forth in the Code of Ethics and Conduct. Eurotrol S.p.A. wants to institute precise disciplinary measures so that no abnormal situations are created at work that could create discrepancies in a homogeneous management of behaviour and procedures. 

More precisely, Eurotrol S.p.A. may adopt the following sanctions in terms of disciplinary measures against employees: 

– verbal reprimand; 

– written reprimand;

– fine of a variable amount up to a maximum of four hours’ pay; 

– suspension from work and from pay for up to a maximum of ten days;

– dismissal without notice.  

11. Disclosure of the Code of Ethics and Conduct

This « Code » issued by Eurotrol S.p.A. is brought to the attention of company personnel and any other third party who may act on behalf of the company. All the aforementioned subjects are required to learn and respect its contents. All the members of Eurotrol S.p.A., shall receive a copy of the « Code » in order to read it, know its contents, and accept them, with a precise written declaration and in order to behave in compliance with the principles it contains. A copy of the « Code of Ethics for Business Conduct » must be displayed in full view on every Eurotrol S.p.A. notice board and a copy of the code of ethics will be published on the website

Settimo Milanese, 15 July 2022

The Legal Representative

Patrizia Leoni