Ethical code

Premise

The Code of Ethics is born with the intent to establish and disseminate principles and behavioral standards that ENGECO considers fundamental for its activity. At the European level, ENGECO is one of the longest-running companies in the field of vertical, high-altitude work, bio-engineering and consolidation. In particular, it operates in the context of structural consolidation of medium and large conduits in masonry and / or concrete that meet the need to ensure the maintenance or rehabilitation of pipelines that, by their nature, location or need for maintenance in exercise, they can hardly be the object of traditional operations. Furthermore, ENGECO has been working for many years to safeguard the national monumental heritage with interventions based on traditional methods for a global conservative rehabilitation and includes, among the sectors of intervention, monumental architectural restoration, the wooden and pictorial restoration, the static consolidation of stone and wood structures, the computerized survey of elevations and details and non-destructive testing diagnostics.

ENGECO guarantees the correct execution of all interventions, through checks and periodic checks of the various operational phases, with qualified technicians and experts in charge of the evaluation of the techniques used. The operators are then coordinated by sector managers according to precise corporate quality procedures. ENGECO conducts its business with integrity, fairness and professionalism and undertakes to carry out all activities in compliance with the law, in a framework of fair competition and in compliance with the legitimate interests of customers, employees, commercial and financial partners and other subjects with whom the Company comes into contact.

The company mission has as its objective the quality and continuous research, fundamental to protect and guarantee the safety of settlements, roads and productive activities from phenomena caused by collapses and environmental instabilities through the use of more innovative operating methods and protection technologies, the all paying particular attention to the environmental and landscape results. To operate in such a complex and delicate field, nothing can be left to chance and only a high degree of specialization and good operational flexibility combined with a great deal of human resources guarantee professionalism, safety and effectiveness of results. To optimize the work, ENGECO always focuses on the quality of the workers and promotes the culture of social responsibility, the value of work, legality, fairness and transparency that are the basis of the company's activities and the essential prerequisites for achieving the productive, economic and social objectives.

To achieve these objectives, ENGECO has adopted this Code, which identifies the company values, the set of rights, duties and responsibilities of all those who, in any capacity, work with the company itself (directors, employees, consultants, agents, commercial partners, Public Administration and, more generally, all the subjects linked by a partnership with the company). ENGECO intends to make sure that all those who work directly and indirectly with the company do not commit

Organization, Management and Control manual pursuant to Legislative Decree 231/2001 crimes that may not only discredit the image of the Company itself, but also entail the application of the sanctions provided for by Legislative Decree no. 231/2001.

ENGECO undertakes therefore to promote and spread the knowledge of this Code to employees, who are asked to know the rules of reference that regulate the activity carried out within their function and the obligation to refrain from behaviors contrary to these rules . Furthermore, ENGECO deemed it necessary to formalize an organizational model suitable to manage the business risk more effectively, and to spread to all stakeholders a document that incorporates the most important deontological principles inspiring its activities.
The Code of Ethics also applies to third parties, who will be adequately informed about the commitments and obligations imposed here.

EMPLOYEES

1Obligations

The Code is an integral and substantial part of the employment contract of each employee. ENGECO requires strict compliance with the provisions of the Code; any violation involves the adoption of adequate sanctions. Therefore, employees are required:

to act in compliance with the law and with the provisions of the Code of Ethics;

  • to observe internal procedures;
  • to implement company policies on the subject of information security to guarantee its integrity, confidentiality and availability;
  • to avoid situations that may create conflicts of interest;
  • to use the entrusted company assets carefully and sparingly;
  • not to prevent or hinder the carrying out of the control or audit activity;
  • not to hinder the functions of public supervisory authorities;
  • in case they become aware of violations, to report the facts to the Supervisory Board for all the identified risk areas.
2Employees in a position of responsibility

Whoever is responsible for a role, or manager, must be an example and with his behavior demonstrate to employees that compliance with the Code is a fundamental aspect of the work.

3Information security

All ENGECO employees are required to protect the data and information owned by the Companies that are in their possession or under their control, refraining or preventing unauthorized disclosures or uses. The information owned by the Company consists of any information or data that the Company uses in its business activity and that is not generally known outside. Acts and materials that contain confidential information must be kept confidential and may not be copied or disclosed, nor to employees, without specific permission from the Summit. All confidential information must be password protected, where it is stored electronically, and / or stored in secure and closed cabinets.

In carrying out its activity, ENGECO collects a significant amount of confidential information (relating to customers, suppliers, staff), which undertakes to process in compliance with the laws regarding the protection of privacy.

4Duty of impartiality and conflict of interests

All must work impartially and must make decisions with rigor and transparency in the conduct of all corporate procedures. Everyone must reject any unlawful pressure in carrying out their business. In the event that they are subjected to pressures, flattery or requests for favors concerning their work or that of others, or receive proposals that tend to reduce the duty of impartiality, they must inform their manager and / or the Organism supervision. Employees or collaborators must avoid any situation that may create a conflict with the interests of the Company or that may interfere with the ability to assume, in an impartial manner, decisions in the best interests of the company and in compliance with the provisions of the Code; in particular, any conflict of interest between the personal and family economic activities and the duties held within the Company must be avoided. Anyone who is even aware of the possibility of a conflict of interest must immediately inform the Supervisory Body.

5Company assets

Employees are required to use company assets and resources to which they have access or are available in an efficient manner and in ways that protect their value.

6Environment and safety

Employees are required to comply with internal rules, procedures and regulations relating to the environment and safety; in particular, any behavior that may be inconsistent with the aforementioned documents and that may be risky for all ENGECO resources must be avoided.

7Management and use of IT systems

Employees are required to comply with the rules, procedures and internal provisions relating to the management and use of IT systems.

EXTERNAL RELATIONSHIPS

1Business relations

ENGECO S.r.l. in business relations it is inspired by the principles of loyalty, integrity, fairness, transparency and efficiency. Administrators, employees, partners, consultants and, in general, all those who collaborate with ENGECO, must follow correct behaviors in the affairs of interest of the Company and in relations with the Public Administration, regardless of the competitiveness of the market and the importance of deal. Practices of corruption, illegitimate favors, collusive behavior, direct solicitations and / or through third parties of personal and career advantages for oneself or for others are prohibited.

2Customers

ENGECO undertakes to treat its customers correctly and honestly on the basis of the following obligations:

  • observe internal procedures for customer management;
  • provide quality products that meet the reasonable expectations and needs of the customer;
  • provide accurate and comprehensive information about the products so that the customer can make informed decisions;
  • stick to truth in communications;
  • avoid practices that are a violation of competition laws.
3Providers

In order to guarantee the highest level of customer satisfaction, in the supply relationships of goods and / or services, the ENGECO is obliged to:

  • observe internal procedures for selecting and managing relationships with suppliers;
  • adopt objective criteria, about competitiveness, quality, economy, price, integrity, in the selection of suppliers;
  • observe the contractually agreed conditions;
  • accepting gifts or courtesy from suppliers only if they are of modest value and comply with the normal commercial and courtesy practices.
4Relations with the Public Administration, political and trade union organisations

Relations with public institutions are reserved exclusively for the functions authorised for this purpose and must be based on transparency and correctness. It is not allowed to correspond or offer, directly or indirectly, payments and material benefits of any entity to third parties, public officials or individuals, to influence or compensate an act of their office. Acts of commercial courtesy, such as gifts or forms of hospitality, are allowed when they are of modest value and in any case such as not to compromise the integrity or reputation of one of the parties and can not be interpreted by an impartial observer as aimed at gain improper benefits. In any case this type of expenses must always be authorised.

SOCIAL COMMUNICATIONS

ENGECO must be administered and managed according to the principles of transparency and fairness, fulfilling all the communication obligations prescribed by the law. In addition, the Company must be managed in such a way that maximum protection of its social assets is achieved, to protect members and creditors. All corporate communications required by law must be drawn up in compliance with the principles, criteria and rules established by the Italian Civil Code and accounting principles, in compliance with tax regulations and all other regulations of the law.

USE OF INFORMATION SYSTEMS

The use of IT tools in the performance of the work tasks entrusted by the Company is subject to the conditions set by the license agreements and by the legal provisions in force as well as by the principles expressed in this Code of Ethics. Every user of IT tools is responsible for the security of the programs and for the correct use of all the data acquired in the performance of their functions. The company's operational managers collaborate with the Supervisory Body in order to ensure the effectiveness of the security systems designed to protect the installations and the traceability of relations with the outside1.

IMPLEMENTING PROCEDURES

For the purposes of a correct interpretation and application of this Code and of the implementation of the related implementation and disciplinary procedures, the Supervisory Body is established, which shall:

  • communicate the operational methods of its function;
  • promote the issuance of guidelines and operating procedures;
  • prepare employee communication and training programs to improve knowledge of the Code;
  • check the knowledge of the code inside and outside of ENGECO and its execution
  • examine the news of possible violations of the Code;
  • communicate to the Summit the results of the relevant checks for the adoption of sanctions.

All ENGECO employees and collaborators who become aware of the violation of the Code of Ethics and / or of the laws or of any suspicious behavior or of any improper operating procedure, are obliged to promptly inform the Supervisory Board, which guarantees anonymity and maximum confidentiality. Any transgressor of the individual rules of conduct prescribed by this Code will be punishable with disciplinary sanctions. The sanctions will be described in detail in a separate document and will be applied, in the case of a subordinate employment relationship, in compliance with art. 7 of the Workers' Statute and the provisions of the collective labor agreements applied.

MODIFICATION OF THE DIFFUSION OF THE CODE

A copy of this Code will be issued to all ENGECO employees and collaborators. All employees will be informed in advance of the existence of the Code of Ethics through an appropriate correspondence and the fission of notices in places accessible to all.