CODE OF ETHICS

Special Part 1^

TABLE OF CONTENTS CODE OF ETHICS

1. Premise: General principles of sustainability and corporate responsibility                            
2. Standards of conduct and relations with stakeholders                                                              

2.1.             Ethics, transparency, fairness, professionalism

2.2.             Relations with institutions, associations and local communities

2.2.1.         Public Authorities and Institutions

2.2.2.         Political and trade union organizations

2.2.3.         Development of local communities

2.3.             Relationships with customers and suppliers

2.3.1.         Customers

2.3.2.         Suppliers and external collaborators

2.4.             Management, employees, collaborators of Tecnica 80

2.4.1. Development and Protection of Human Resources

2.4.2. Knowledge Management

2.4.3. Business Security

2.4.4. Harassment or mobbing in the workplace

2.4.5. Alcohol or Drug Abuse and Smoking Prohibition

3. Tools for applying the Code of Ethics                                                      

3.1.             Internal control system

3.1.1.         Conflicts of interest

3.1.2.         Transparency of administrative and accounting management

3.2.             Protection of health, safety and environment and public safety

3.3.             Research, innovation and protection of intellectual heritage

3.4.            Confidentiality

3.4.1.         Protection of Business Secrets

3.4.2.         Privacy Policy

4. Obligation to be aware of the Code and to report possible violations                                                  

4.1. Referral structures and supervision

4.2. Control function of the Code of Ethics

4.3. Adoption and revision of the Code

4.4. Consequences in case of violations of this Code of Ethics

 

 

GENERAL ETHICAL PRINCIPLES

PREMISE

Tecnica 80 is a company with an international vocation that is aware, in the light of its role in the electromechanical sector with niche products that meet the needs of large industrial groups, of playing a role aimed to the economic development and well-being of the people who work or collaborate with the company itself.

The complexity of the situations in which Tecnica 80 operates, the challenges of sustainable development and the need to consider all the legitimate stakeholders in the company’s activities (“Stakeholders”), reinforce the importance of clearly defining the values and responsibilities that Tecnica 80 recognizes, accepts, shares and assumes unconditionally.

For this reason has been drawn up this company’s Code of Ethics (“Code of Ethics”), the observance of which by the directors, management and all employees of Tecnica 80, as well as by all those who work to achieve the objectives of the same company, each within the scope of their functions and responsibilities, is of fundamental importance for efficiency,  the reliability and reputation of Tecnica 80; factors that constitute a decisive asset for the success of the company and for the improvement of the social context in which Tecnica 80 operates.

The principles and contents of the Code of Ethics apply to the personnel and activities carried out by Tecnica 80, inspiring their work. It is primarily the responsibility of the Directors to give substance to the principles and contents of this Code of Ethics, taking charge of them, both inside and outside the company, and strengthening trust, cohesion and team spirit, and also representing with their conduct an example for their collaborators and/or employees, directing them to comply with this Code.

Tecnica 80 is therefore committed to promoting the knowledge of this Code of Ethics by all the staff of the company itself, of the other Stakeholders, and to promote their constructive contribution to the principles and contents of the Code itself, with the aim of integrating and/or improving the latter.

In any case, Tecnica 80 carefully supervises, also through the appointed Supervisory Body, compliance with this Code, preparing adequate tools and documents for information, prevention and control and ensuring the transparency of the operations and conduct carried out, intervening, if necessary, with corrective actions.

1. GENERAL PRINCIPLES OF SUSTAINABILITY AND CORPORATE RESPONSIBILITY.

Compliance with the law, regulations, statutory provisions, codes of conduct, ethical integrity and fairness are the constant commitment and duty of all Tecnica 80 personnel and/or its collaborators, including external ones, and must characterize the conduct of its entire organization.

The conduct of Tecnica 80’s business and corporate activities must be carried out within a framework of transparency, honesty, fairness, good faith and in full compliance with the rules put in place to protect competition.

Tecnica 80 is committed to maintaining and strengthening a management system aligned with the standards required at national and/or international level, capable of managing the complexity of the situations in which Tecnica 80 operates, and the challenges to be faced for sustainable development.

Systematic forms of stakeholder involvement are adopted, extending the dialogue on the issues of sustainability and corporate responsibility.

In the development of its business activities, Tecnica 80 is inspired by the protection and promotion of human rights, inalienable and essential prerogatives of human beings and the foundation for the construction of societies based on the principles of equality, solidarity, the protection of civil and political rights, social, economic and cultural rights and the so-called third generation rights (right to self-determination, peace, development and environmental protection).

It is repudiated by the company Tecnica 80, all kinds of discrimination, corruption, forced or child labor. Particular consideration shall be given to the recognition and safeguarding of the dignity, freedom and equality of human beings, the protection of labor and trade union freedoms, health, safety, the environment and biodiversity, as well as the system of values and principles on transparency, energy efficiency and sustainable development, as affirmed by International Institutions and Conventions.

In this regard, Tecnica 80 operates in compliance with the provisions of the laws and national regulations, as well as with the international provisions of the United Nations Universal Declaration of Human Rights and the following conventions:

• the Convention on the Protection of the European Communities’ Financial Interests (Brussels, 26 July 1995) and its First Protocol (Dublin, 27 September 1996);
• the Convention on the fight against corruption involving officials of the European Communities or officials of the Member States of the European Union (Brussels, 26 May 1997);
• the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Paris, 17 December 1997).

In addition, Tecnica 80 is inspired by the provisions of the most advanced national legislation on the fight against corporate crime and, in particular, by the prevention and control safeguards and mechanisms contemplated and/or recalled in the aforementioned regulatory provisions.

All Tecnica 80 personnel, without distinction or exception, as well as their collaborators (both internal and external), must adapt their actions and conduct to the principles and contents of this Code of Ethics within the scope of their functions and responsibilities, in the awareness that compliance with the Code is an essential part of the quality of work and professional performance. The relationships maintained by Tecnica 80, at all levels, must be based on criteria and behaviors of honesty, fairness, collaboration, loyalty and mutual respect. In no way can the conviction of acting for the benefit or in the interest of Tecnica 80 justify, even in part, the adoption of conduct contrary to the principles and contents of this Code.

 

2. STANDARDS OF CONDUCT AND RELATIONS WITH STAKEHOLDERS.

2.1. Ethics, transparency, fairness, professionalism.

Tecnica 80 in all its business relationships is inspired by and observes the principles of loyalty, fairness, transparency, honesty, integrity and efficiency, without distinction of the importance of the business. All actions, operations and negotiations carried out and, in general, the conduct carried out by the personnel and management of Tecnica 80 in the performance of their function and activities, must be inspired by the utmost correctness, completeness and transparency, avoiding deceptive conduct and/or undue advantage, as well as their legitimacy, both from a formal and substantive point of view.

Likewise, the information provided by the staff and management of Tecnica 80 must be clear, truthful, complete and transparent.

All the activities of Tecnica 80 must be carried out with commitment and professional rigor, with the duty to provide professional contributions appropriate to the functions and responsibilities assigned and to act in such a way as to protect the prestige and reputation of Tecnica 80. The company’s objectives, the proposal and implementation of projects, investments and actions, must all be aimed at increasing the company’s assets, management, technology and knowledge values in the long term, as well as the creation of value and well-being for all stakeholders; always and in any case in compliance with the laws, regulations and customs in force, as well as with the principles contained in this Code of Ethics.

Corrupt practices, illegitimate favors, collusive behavior, solicitation, direct and/or through third parties, of personal and career advantages for oneself or for others, are without exception, prohibited.

It is never permitted to pay or offer, directly or indirectly, payments, material benefits and other advantages of any entity to third parties, representatives of governments, public officials and public or private employees, to influence or compensate an act of their office.

It is forbidden to accept money from persons or companies that are or intend to enter into business relationships with Tecnica 80. Anyone who receives proposals for gifts or preferential treatment or hospitality that cannot be considered as acts of commercial courtesy of modest value, or the request for such by third parties, must refuse them and immediately inform the hierarchical superior, or the body to which he belongs, as well as the Supervisory Body.

Tecnica 80 takes care to adequately inform third parties about the commitments and obligations imposed by this Code of Ethics, and requires third parties to comply with the principles of the Code itself in carrying out their activities; as well as adopts the appropriate internal and/or external initiatives, in the event of non-compliance and/or compliance by third parties, with the principles set out in this Code of Ethics.

2.2. Relations with institutions, associations and local communities.

Tecnica 80 also promotes dialogue with institutions and with all the organized realities of civil society.

2.2.1. Public Authorities and Institutions.

Tecnica 80, through its staff, actively and fully cooperates with the Authorities. All Tecnica 80 personnel, as well as external collaborators whose actions may be attributable to Tecnica 80, must behave in a manner characterized by correctness, transparency and traceability in their relations with the Public Administration.

It is forbidden to make, induce or facilitate false statements to the Authorities.

2.2.2. Political and Trade Union Organizations.

Tecnica 80 does not make contributions, direct or indirect, in any form, to political parties, movements, committees and political organizations, to their representatives and candidates. The disbursement of direct or indirect contributions in favor of trade unions and their representatives is permitted, within the limits and to the extent that this is provided for by mandatory legislative requirements or by the applicable collective bargaining agreement.

2.2.3. Development of Local Communities.

It is Tecnica 80’s commitment to actively contribute to the promotion of the quality of life, the socio-economic development of the communities in which the company operates and the formation of human capital, while at the same time carrying out its business activities in a manner compatible with correct business practice.

Tecnica 80’s activities are carried out in the awareness of the social responsibility that it has towards all its stakeholders and in particular the local communities in which it operates, in the belief that the ability to dialogue and interact with civil society represents a fundamental value of the company.

2.3. Relations with customers and suppliers.

2.3.1. Customers.

Tecnica 80 pursues its business objective on the markets through the offer of quality goods and services and in compliance with all the rules put in place to protect fair competition.

Tecnica 80 undertakes to respect the right of customers not to receive products that are harmful to their health and physical integrity, and to provide complete information on the offered products.

The company’s commercial policies are aimed at ensuring the quality and safety of the goods and services offered. It is therefore mandatory for all Tecnica 80 personnel to:

• comply with all current regulations governing the management of customer relations;
• to provide, efficiently and courteously, within the limits of the contractual provisions, high quality goods and services that meet the reasonable expectations and needs of customers;
• Provide accurate and comprehensive information about goods and services rendered, and adhere to truthfulness in advertising or other communications, so that customers can make informed decisions.

2.3.2. Suppliers and External Collaborators.

Tecnica 80 undertakes to require suppliers and external collaborators to be suitable for professionalism and commitment to sharing the principles and contents of this Code of Ethics, promoting the formation of lasting relationships with the same suppliers and collaborators, for the progressive improvement and promotion of the principles and contents of the Code of Ethics itself. In the procurement, provisioning and, in general, supply of goods and/or services and external collaboration (including consultants, agents, etc.) all Tecnica 80 personnel are required to:

• to comply with the regulations in force, for the selection and management of relations with suppliers and external collaborators, and not to preclude any person in possession of the required requirements, the possibility of competing to establish professional and/or commercial relationships with Tecnica 80 itself; as well as adopting, in the relevant selection activity, only objective and deserving evaluation criteria, in a clear and transparent manner;
• obtain the collaboration of suppliers and external collaborators in constantly ensuring the satisfaction of customer needs to an extent adequate to their legitimate expectations, in terms of quality, cost and delivery times;
• include in the contracts the confirmation of having read this Code of Ethics, and the express obligation to comply with the principles contained therein;
• observe and require compliance with the contractual conditions;
• maintain a frank and open dialogue with suppliers and external collaborators, in line with good business practices; promptly report to own hierarchical superior, and to the Supervisory Body, any noticed violations of this Code, by whomsoever committed;
• promptly bring to the attention of the competent corporate bodies any significant problems that have arisen with a supplier or an external collaborator, so as to be able to assess the consequences, from any point of view, for Tecnica 80 itself;
• finally, the remuneration to be paid to third parties for any supply and/or professional service must be exclusively commensurate with the service indicated in the contract and payments may not in any way be made to a party other than the contractual counterparty, nor in a third country other than that of the parties or the execution of the contract.

2.4. Management, Employees, Collaborators of Tecnica 80.

2.4.1. Development and Protection of Human Resources.

The dedication and professionalism of the management (directors and top management) and of the company’s employees and external collaborators are decisive values and conditions for achieving the objectives set by Tecnica 80.

The company is committed to developing the skills and competencies of management and employees, so that, in the context of work performance, the energy and creativity of individuals find full expression for the realization of their potential, and to protect working conditions both in the protection of the psycho-physical integrity of the worker and in respect of his or her dignity. Illicit conditioning or undue hardship is not permitted, and working conditions are promoted in a way that allows the development of the personality and professionalism of the person.

Tecnica 80 undertakes to offer, in full compliance with the relevant legal and contractual regulations, the same job opportunities to all workers and/or external collaborators, ensuring that everyone can enjoy a fair regulatory treatment and remuneration based exclusively on criteria of merit and competence, without any discrimination.

The competent bodies of Tecnica 80 must:

• in any case, adopt criteria of merit and competence (and in any case strictly professional) for any decision relating to human resources;
• in any case, select, hire, train, remunerate and manage human resources without any discrimination;
• create a working environment in which personal characteristics or orientations cannot give rise to discrimination and capable of promoting the serenity of all Tecnica 80 personnel.

The company and its management hope that its staff (employees and/or external collaborators) will maintain a climate of mutual respect for the dignity, honor and reputation of each individual in the company and/or in their relations with the company. Tecnica 80 will intervene to prevent abusive, discriminatory or defamatory interpersonal attitudes. To this end, extra-work behaviors that are particularly offensive to civil sensibilities are also considered relevant.

In any case, without exception, conduct that constitutes physical or moral violence is prohibited.

2.4.2. Knowledge Management.

Tecnica 80 is committed to promoting the process of managing, cataloguing, preserving and updating the company’s knowledge assets; this is done in order to implement and disseminate the related knowledge within its structures and to highlight the values, principles and behaviors and contributions in terms of innovation of its products.

All Tecnica 80 personnel are required to actively contribute to the Knowledge Management processes in the activities of their respective competence, in order to optimize the system of sharing and distributing the knowledge between the individual company sectors.

2.4.3. Enterprise Security.

Tecnica 80 undertakes to prevent and/or preclude any negligent or intentional conduct that may cause direct or indirect damage to Tecnica 80 personnel. (as well as to third parties external to the same company, such as collaborators, consultants, agents, etc.) and/or to the company’s tangible and intangible resources. All Tecnica 80 personnel are required to actively contribute to maintaining an optimal standard of company safety, refraining from illegal or otherwise dangerous behavior and reporting to their hierarchical superior any activities carried out by third parties to the detriment of the assets or human resources of Tecnica 80 itself.

It is mandatory to scrupulously comply with the instructions provided by the company, refraining from conduct that may put one’s own or others’ safety at risk, promptly reporting to one’s hierarchical superior any situation of danger to one’s own safety or that of third parties.

2.4.4. Harassment or mobbing in the workplace.

Tecnica 80 promotes initiatives aimed at creating working methods aimed at achieving the greatest organizational well-being.

Technique 80 requires that in internal and external employment relations there is no harassment or attitudes that can be traced back to mobbing practices, which are all, without exception, prohibited.

The following are considered as such:

• create an intimidating, hostile, isolating or otherwise discriminatory work environment against individuals or groups of workers;
• unjustifiably interfere with the performance of the work of others;
• hinder the individual employment prospects of others for the mere reasons of personal competitiveness or that of other employees.
• Any form of violence or harassment, including sexual violence or related to personal and cultural diversity, is prohibited.
• The following are considered as such:
• make any decision of relevance to the recipient’s working life subject to the acceptance of sexual favors, or in any case to personal and/or cultural differences;
• induce their collaborators to sexual favors through the influence of their role;
• propose private interpersonal relationships, despite an express or reasonably obvious dislike;
• allude to physical or mental disabilities and/or impairments or to forms of cultural, religious or sexual orientation diversity.

2.4.5. Alcohol or Drug Abuse and Smoking Prohibition.

All Tecnica 80 personnel must personally contribute to promoting and maintaining a climate of mutual respect in the work environment; particular attention is paid to the conditions of respect for the sensibilities of others.

It will be considered a conscious assumption of the risk of impairing these environmental characteristics, being or being under the influence of alcohol, narcotic substances or substances with a similar effect, during the course of work and in the workplace. States of chronic dependence, when they affect the work environment, will be – due to contractual repercussions – equated to previous cases; Tecnica 80 is committed to promoting the social actions planned in this area by employment contracts.

In any case, it is forbidden to:

 possessing, consuming, offering or disposing of drugs or substances with a similar effect for any reason, in the course of work and in the workplace;

 Smoking in the workplace. Tecnica 80 favors the identification of areas reserved for smokers, taking into particular consideration the condition of those who feel physical discomfort due to the possible presence of smoke in situations of cohabitation at work and ask to be protected from contact with “passive smoking” in their workplace.

 

3. TOOLS FOR THE APPLICATION OF THE CODE OF ETHICS.

3.1. Internal control system.

Tecnica 80 is committed to promoting and maintaining an adequate internal control system, to be understood as the set of all the tools necessary or useful for directing, managing and verifying business activities, with the aim of ensuring compliance with the laws and regulatory provisions in force; to protect company assets, to manage business activities optimally and efficiently, as well as to provide those responsible with accurate and complete accounting and financial data.

The responsibility for implementing an effective internal control system is common to every level of the organizational structure of Tecnica 80 itself, and consequently, all the latter’s personnel undertake to actively participate in the proper functioning of the internal control system. In addition, everyone is the responsible custodian of the assigned company assets (tangible and intangible) that are instrumental to the activity carried out; no employee may make, or allow others, to misuse the assigned assets and company resources.

Practices, attitudes or behaviors that can be traced back to the commission of or participation in the commission of fraud are prohibited, without exception. The control and supervisory bodies, and where appropriate, the appointed auditing firm, have free access to the data, documentation and information useful for carrying out their own activities.

3.1.1. Conflicts of Interest.

All managerial and top management staff, as well as employees of Tecnica 80, are required to avoid and report any conflicts of interest between personal and family economic activities, and the duties they hold within the company structure. This is because every business decision must be taken in the interest of the company Tecnica 80, albeit in full compliance with the laws, regulations and customs in force, as well as the principles of this Code of Ethics.

In particular, each person is required to report the specific situations and activities in which he/she or, to the best of his/her knowledge, his/her spouse, relatives and related, have economic and financial interests (owner or partner) in suppliers, customers or competitors, or hold corporate administrative or control roles, i.e. managerial ones.

In addition, the following situations give rise to conflicts of interest:

• use of one’s position in the company or of the information or business opportunities acquired in the exercise of one’s office, for one’s own or third party’s undue benefit;
• performance of work activities by the employee and/or his/her family members with suppliers, subcontractors, competitors of Tecnica 80 itself.

In any case, the management and employees of Tecnica 80 are required to avoid all situations and activities in which there may be a conflict with the interests of the company itself, or which may interfere with their ability to take, in an impartial manner, decisions in the best interests of Tecnica 80 itself and in full compliance with the principles and contents of this Code of Ethics,  or, in a general sense, to perform exactly the functions performed by them, with the necessary responsibility required.

Any situation that may constitute or determine a conflict of interest must be promptly communicated in written form to any corporate officers possibly in charge and superordinate and to the Supervisory Body.

The person involved must promptly refrain from intervening in the operational/decision-making process. In particular, the Supervisory Body, in the event of a presumed conflict of interest:

• ascertains the existence or otherwise of the conflict and identifies the operational solutions to safeguard, in the specific case, the transparency and correctness of the conduct in the performance of the activities;
• consequently, if the aforementioned conflict of interest is identified, it communicates to the interested parties (in particular to the Directors not in conflict of interest) the necessary written instructions to resolve the aforementioned conflict of interest.

3.1.2. Transparency of Administrative and Accounting Management.

The administrative and accounting transparency of the company Tecnica 80 is based on compliance with all laws, regulations and customs in force on the subject, as well as on scrupulous compliance with the truth, accuracy, congruity and completeness of the information on which the relevant accounting records are based. Each member of the company is required to collaborate, within the scope of its competences, so that the management facts are correctly and promptly represented in the accounting records and in the related administrative documentation of reference.

It is forbidden to engage in conduct that may prejudice the transparency and traceability of financial statement information, and any type of mandatory administrative-accounting documentation.

For each operation, adequate supporting documentation of the activity carried out is kept in the records, in order to allow and facilitate:

• easy and punctual accounting entry;
• the identification of the different levels of responsibility and division of tasks;
• the accurate reconstruction of the operation, also to reduce the probability of errors, even if simply material or interpretative;
• the access to and verification of control bodies, both internal and/or external of the company Tecnica 80 itself; to this end, the control or auditing activities assigned to the shareholders, to the relevant corporate bodies, to the auditing firm possibly appointed, and ultimately to the supervisory body may not be impeded or hindered.

Each record must reflect exactly what is reflected in the supporting documentation. It is the responsibility of all Tecnica 80 personnel, and within the limits of their respective functions, to ensure that the documentation is easily traceable and ordered according to logical criteria.

The staff and/or management of Tecnica 80, if they become aware of omissions, falsifications, negligence in keeping the accounts or administrative documentation on which the accounting records are based, are required to promptly report these facts to their superior if employed, or to the relevant company bodies, if such knowledge has been acquired by a third party; without prejudice in any case to the ability/duty to report to the appointed Supervisory Body.

3.2. Protection of health, safety and the environment and public safety.

Tecnica 80’s activities must be conducted in accordance with international agreements and standards, as well as national laws, regulations, administrative practices and national policies relating to the protection of workers’ health and safety, the environment and public safety; with particular reference to the provisions of Legislative Decree no. 81/2008 and related prevention provisions.

In particular, Tecnica 80 is inspired by the following principles in the field of health and safety at work:

• prevent and assess risks in order to identify increasingly efficient prevention measures;
• adopt equipment and working and production methods always aimed at reducing the effects on health, with particular attention to technical evolution;
• tend to avoid what is dangerous for the worker by replacing it with what is less dangerous for the worker himself;
• give adequate and detailed instructions to workers in order to avoid as much as possible dangers to the safety of the worker himself.

For the above, Tecnica 80 also pays particular attention to the promotion of scientific and technological development aimed at safeguarding resources and the environment. Operational management must refer to advanced criteria of environmental protection and energy efficiency, pursuing the continuous improvement of health and safety conditions at work and environmental protection.

As part of their duties, Tecnica 80 personnel actively participate in the process of risk prevention, environmental protection and public safety, and health and safety protection for themselves, colleagues and third parties.

Tecnica 80 also guarantees workers’ freedom of association and recognizes the right to collective bargaining. It undertakes not to use, even indirectly, both compulsory labor and child labor that does not comply with current national legislation. Rejects any discrimination related to age, sex, state of health, race, nationality, political or religious opinions; It rejects all forms of discrimination in recruitment policies and human resources management. Tecnica 80 is committed to preventing all forms of mobbing and exploitation of labor, both direct and indirect, and to identifying merit, work performance and professional potential as the decisive criteria for salary and career development. In addition, Tecnica 80 undertakes not to establish commercial relationships with suppliers who do not comply with the aforementioned principles regarding the safety, health and employment of workers.

 

3.3. Research, innovation and protection of intellectual heritage.

Tecnica 80 is committed to promoting research and innovation activities by management and employees, within the scope of the functions and responsibilities held. The intellectual assets generated by this innovative activity constitute a central and essential asset of Tecnica 80. Research and innovation are dedicated in particular to the promotion of goods, tools, processes and behaviors that are increasingly favorable, also in terms of energy efficiency, the reduction of environmental impact, attention to the health and safety of employees, customers and the local communities in which Tecnica 80 operates, and in general for the sustainability of business activities. The staff of Tecnica 80 is required to actively contribute, within the scope of the functions and responsibilities held, to the protection and maintenance of the intellectual heritage and know-how acquired by the company, to allow its development, protection and enhancement.

3.4. Confidentiality.

3.4.1. Protection of Business Secrets.

The activities of Tecnica 80 constantly require the acquisition, storage, processing, communication and dissemination of news, documents and other data relating to negotiations, administrative procedures, financial transactions, know-how (contracts, deeds, reports, notes, studies, drawings, photographs, software, etc.) which, due to contractual agreements, cannot be disclosed externally or whose inappropriate or untimely disclosure could cause damage to the interests of the Company.

Therefore, without prejudice to the transparency of the activities carried out and the information obligations imposed by the provisions in force, it is the obligation of the entire staff of Tecnica 80 to ensure the confidentiality required by the circumstances for each piece of information learned by reason of their work function.

The information, knowledge and data acquired or processed during one’s work or through one’s duties belong to Tecnica 80 and may not be used, communicated or disclosed without specific authorization from the latter’s Directors, but always in compliance with the legal regulations in force on the subject.

 

 

3.4.2. Privacy Policy.

Tecnica 80 undertakes to protect the information relating to its personnel and/or third parties, purchased in the course of its business activities, and to avoid any improper use of this information. Tecnica 80 intends to ensure that the processing of personal data carried out within its facilities takes place in compliance with fundamental rights and freedoms, as well as the dignity of the data subjects, as provided for by national, EU and international regulations on privacy.

The processing of personal data must be carried out in a lawful and correct manner and, in any case, only data necessary for specified, explicit and legitimate purposes are collected and recorded. The data will be stored for a period of time not exceeding that necessary for the purposes of collection and in any case in compliance with the relevant laws in force.

Tecnica 80 also undertakes to adopt suitable and preventive security measures for all the databases in which the personal data acquired are collected and stored, in order to avoid the risk of destruction and loss or unauthorized access or unauthorized processing.

The entire staff of Tecnica 80 is therefore committed:

• to acquire and process only the data necessary and appropriate for the company’s purposes;
• to acquire and process the data only in compliance with specific regulatory provisions, as well as to store and archive the data in such a way as to prevent unauthorized others from becoming aware of it;
• to collect and order the data in such a way that any person authorized to access it can easily draw a picture that is as precise, exhaustive and truthful as possible;
• to communicate the data in strict compliance with current legislation, or with the express authorization of the hierarchical superior; and in any case, however, only after verifying their disclosureability in the specific case, and if there are constraints on their disclosures concerning third parties connected to Tecnica 80 by a relationship of any kind, only after obtaining their consent.

Finally, the employees, collaborators and consultants of Tecnica 80 are required not to use the information acquired in the performance of their activity except for purposes strictly related to the exercise of the same.

4. OBLIGATION TO BE AWARE OF THE CODE AND TO REPORT POSSIBLE VIOLATIONS.

Tecnica 80 undertakes to ensure that recipients are aware of this Code of Ethics through appropriate knowledge and disclosure tools.

The staff of Tecnica 80 is required to be familiar with the principles and contents of this Code of Ethics, as well as the reference regulations that govern the functions and responsibilities covered by each one.

The staff and management of Tecnica 80 are required to:

• refrain from conduct contrary to the aforementioned principles, contents and regulatory precepts;
• carefully select, as far as it is competent, its collaborators and direct them to full compliance with this Code of Ethics;
• request from third parties with whom Tecnica 80 collaborates commercially, confirmation that they have read this Code;
• promptly report to the Supervisory Body any findings or information provided by Stakeholders about possible cases or requests for violations of the Code;
• cooperate with the Supervisory Body and the Directors on the specific provisions for the verification of possible violations;
• take immediate corrective measures when the situation requires it and, in any case, prevent any kind of retaliation.

Without prejudice to the fact that he/she will not be able to conduct personal investigations or report the news to anyone other than the Directors and the Supervisory Body, if after reporting the news of a possible violation, the person who made such a report believes that he/she has suffered retaliation, he/she may contact the Supervisory Body directly.

4.1. Referral structures and supervision.

Tecnica 80 is committed, also through the Supervisory Body, to ensure:

• the maximum disclosure of the principles and contents of this Code, to all the personnel of Tecnica 80 and other Stakeholders; the provision of all possible cognitive and clarification tools for the interpretation and implementation of this Code as well as for the updating of the Code in order to adapt it to the evolution of civil sensitivity and relevant regulations;
• carrying out checks on any report of violation of the principles and contents of this Code of Ethics and the relevant regulatory precepts; the objective assessment of the facts and the consequent implementation, in the event of an ascertained violation, of appropriate sanctioning measures;
• that no one may suffer retaliation of any kind for having provided information of possible violations of this Code or of the relative regulatory precepts.

4.2. Control function of the Code of Ethics.

The function of monitoring the Code of Ethics and its regular observance is carried out mainly, in addition to the directors of Tecnica 80, by the appointed Supervisory Body, who have the task of:

• promote the implementation and observance of this Code of Ethics, also identifying useful initiatives for greater disclosure and knowledge of the Code, also in order to avoid the recurrence of ascertained violations;
• promote communication programs and specific training of the management and employees of Tecnica 80, with regard to the knowledge of the principles and dictates contained in this Code of Ethics;
• examine reports of possible violations of this Code, promoting the most appropriate checks; intervene, even on the recommendation of Tecnica 80 staff, in cases of news of possible violations of the Code deemed not to have been duly addressed or retaliation suffered by the person following the reporting of news;
• communicate to the Supervisory Body the results of the relevant checks for the adoption of any sanctioning measures; inform the Supervisory Body of the results of the relevant checks for the adoption of the appropriate measures.

In order to facilitate the flow of reports, and guarantee their anonymity, confidentiality and avoid any possible retaliation and/or discrimination for those who make the report, Tecnica 80 has adopted appropriate measures in accordance with the current legislation in force on whistleblowing.

4.3. Adoption and revision of the Code.

The adoption and possible revision of this Code of Ethics is approved by the Administrators of Tecnica 80 in collaboration with the Supervisory Body.

Any amendment is formulated also taking into account any suggestions and/or reports of any deficiencies by the Stakeholders with reference to the principles and contents of this Code of Ethics.

4.4. Consequences in case of violation of this Code of Ethics.

All employees, management and collaborators outside Tecnica 80 are required to comply with the principles and dictates of this Code of Ethics.

Therefore, the violation of the principles and contents of the aforementioned Code may constitute a disciplinary offence, with all legal consequences also with regard to the maintenance of the employment relationship, and result in compensation for the damages deriving from the fact itself.