Ethical code


C.S.O. Srl


The C.S.O. Company Srl (hereinafter "C.S.O."), carries out its activity in compliance with the laws and regulations in force in all the countries in which it operates.
C.S.O. it operates in accordance with the principles of freedom, individual dignity and respect for diversity, and rejects all forms of discrimination concerning differences in sex, race, language, religion, political opinions, personal and social conditions.
C.S.O. aims to build its growth and consolidate its image, faithful to values ​​of fairness and loyalty, in every process of daily work. This also in order to take care of the good reputation of the company, a resource of great value both in relations with the market and in relations with investors.
For this purpose C.S.O. favors a work environment inspired by respect, fairness and collaboration and allows the involvement and accountability of employees and collaborators, with regard to the specific objectives that arises to the methods adopted to achieve them.
In implementation of the provisions of Legislative Decree 231 of June 8, 2001, with the publication of this Code of Conduct 231, adopted by the Administrative Body on 12/12/2011, C.S.O. establishes specific rules of conduct to which all subjects with whom it comes into contact must comply.
To ensure compliance with the Code of Conduct 231 C.S.O. has set up a specific Supervisory Body.
Any variation and / or integration of this Code will be previously approved by the Administrative Body and promptly disseminated to the Recipients referred to in point 1.2 below.

1.1 Nature and objectives of the 231 Code of Conduct
The Code of Conduct 231 is an official document which sets the ethical principles that C.S.O. respects, in which it is reflected and to which all subjects with whom it comes into contact must be inspired; expresses the ethical commitments and responsibilities assumed by its collaborators in conducting company activities.
The 231 Code of Conduct is aimed at making clear and clear, unequivocal and comprehensible to all those who work within or who are otherwise linked to C.S.O. respect for the aforementioned ethical principles.
1.2 Recipients of the 231 Code of Conduct
They are distinguished in obligatory recipients and therefore punishable in case of violations and in non-obligatory recipients.
These are obligatory recipients of the Code and as such are obliged to observe the principles contained therein, the directors, statutory auditors, shareholders, employees, managers, collaborators as well as any person exercising the management and control of CSO, regardless of legal-formal qualification.
Also obligatory Recipients of the Code are all collaborators who have a working relationship of any kind, even occasional, with CSO, agents, parasubordinate workers, partners, suppliers, consultants and anyone who carries out activities in the name and on behalf of CSO or under the control of the same.
They are non-obligatory recipients and therefore not subject to sanctions for violation of the provisions of the Code: suppliers, consultants and partners when they do not carry out activities in the name or on behalf of it, as well as the beneficiaries of the C.S.O. and all the stakeholders of interest to the same.
With regard to non-obliged recipients, compliance with and sharing of the Code may constitute a criterion for the selection of subjects with whom to establish or maintain relationships. It is the responsibility of the competent function to obtain from these parties the assumption of the commitment to comply with the 231 Code of Conduct.
1.3 General principles of behavior
C.S.O. conducts its business with integrity, fairness and professionalism, in order to pursue the statutory purposes and the realization of its mission. Avoid any conduct that may facilitate or give rise to the suspicion of the commission of any type of offense, undermining the trust, transparency or tranquility of the work environment and the economic environment in which it operates.
All subjects related to C.S.O. they must show moral integrity in the actions taken on behalf of the same.


2.1 Relations with the Public Administration
C.S.O. reports with public officials, with public employees (in charge of public service or not) and with public service concessionaires, they must be based on transparency, legality and fairness.
To this end, in relations with the Public Administration C.S.O. it will avoid being represented by a single physical person, in order to minimize the risk of interpersonal relationships not consistent with the Company's will; in the event that this is not possible, the traceability of the relationship is guaranteed.
Each person, in relations with the Public Administration must comply with the obligations to inform C.S.O. and of the Supervisory Body; must make available and accessible documents and documents produced within the scope of their functions; he will not have to promise money or other benefits to obtain a legitimate act that complies with the duties of a public official.
It is not allowed to directly or indirectly behave in such a way as to influence any decision of the Public Administration; it is not allowed to send false or artfully formulated administrative and accounting documents, certify any non-existent requirements or give guarantees that do not correspond to the truth; it is not permitted to give or promise gifts, money or other benefits to public officials and public service employees in order to influence the impartiality of their professional judgment or obtain favorable conditions to the detriment of the Public Administration.
It is not allowed to examine or propose employment and / or commercial opportunities that may benefit employees of P.A. in the interest of the Company. In particular, C.S.O. does not assume or assign any type of professional task nor undertakes any economic activity with public officials or public employees and their relatives and similar within the 3rd degree, even indirectly through a third party, who have participated in administrative procedures (contractual or not) or judicial , bringing benefits to CSO in the last 3 months.
If the relations with the Public Administration provide for the payment of commissions or commissions, who, by authorizing these payments to agents or other intermediaries, has a well-founded suspicion that part of these payments or fees may be used to bribe or influence the decision of a public official , must immediately inform the Supervisory Body.
These provisions also apply to payments made to foreign public entities.
2.2 Gifts, gifts and benefits
It is forbidden any form of gift to public officials, Italians or foreigners, or to their family members, that could influence their behavior, the independence of judgment or could induce to secure any advantage for C.S.O.
2.3 Loans, public disbursements and profits paid by P.A.
C.S.O. it must not in any way unjustly achieve profits against P.A .; therefore it does not have to:
• receive unduly - through false documents (or evidence of untrue things), or through the omission of due information - contributions, loans, reimbursements, subsidized loans or other disbursements by the Pa .;
• use grants, subsidies or public funding for purposes other than those for which they are granted;
• draw up false reports or issue false documents regarding the use of the aforementioned loans or on commercial relations with P.A. regulated by reporting mechanisms;
• failing, in whole or in part, of contractual obligations towards the PA, or providing services other than those contracted;
• illegally obtaining to itself or the Company any other type of profit (licenses, authorizations, tax relief, tax benefits or non-payment of social security contributions, etc.) to the detriment of the Public Administrations;
• undertake economic activities, confer professional appointments, give or promise gifts, money, or other benefits to public officials or public employees involved in administrative proceedings that may entail benefits for the Company;
• alter in any way the functioning of a computerized or telematic system of the P.A. or intervene without rights in any manner on data, information or programs contained in one of the aforementioned systems.
2.4 Funding to parties, political and trade union organizations

C.S.O. reports with movements, committees, political and trade union organizations, in Italy and abroad, and with their officials, agents or candidates are inspired by the ethical principles of fairness and respect for the law. C.S.O. does not make contributions to the aforementioned entities, except within the limits established by law and upon the resolution of the Administrative Body. Any contributions paid in compliance with the above must be recorded in the accounting records.
The Company will not reimburse political contributions, granted in a personal capacity by employees, managers, directors, auditors and other subjects connected to it.
It is also forbidden any practice referable to the c.d. "Exchange rate" aimed at obtaining an unfair advantage for C.S.O. to the detriment of the Public Administration.


3.1 Accounting transparency and corporate information
Social communications must be drawn up in compliance with the principles, criteria and rules established by the Civil Code and accounting standards. In compliance with the law, they must meet criteria of truthfulness, accuracy, completeness and clarity, also in order to guarantee to shareholders and third parties a clear picture of the Company's economic, asset and financial situation.
All the directors, statutory auditors, managers, employees and collaborators of C.S.O. are obliged to execute any complaint, communication and filing in the register of companies, within the terms prescribed by law and promptly report to the Supervisory Board, any omission, imprecision or falsification of accounting records or supporting documents they have become aware of .
To avoid giving or receiving undue payments the following principles must be respected:
• all payments and other transfers of currency made by / to the Company also from / abroad must be accurately and fully recorded in the accounting books and compulsory entries;
• all payments must be made exclusively to the legitimate recipients and for the activities contractually formalized;
• false, incomplete or misleading registrations must not be created, and no secret or unregistered funds should be established, nor can funds be deposited in personal accounts or non-members of the institution;
• no unauthorized use of C.S.O funds must be made.
3.2 Proxies and delegations
No one should have powers of representation, direction and management outside of specific delegations and of the system of authorizations and approvals for the assumption of operational, financial and investment management decisions existing within C.S.O.
All activities carried out by C.S.O. or by third parties in the name and on behalf of C.S.O. they must be in a confidentiality regime:
• legitimate and respectful of rules, procedures and regulations;
• open to objective analysis and verification, with precise identification of the subjects involved;
• based on correct and complete information.
In particular, the delegation system must ensure that:
• no person is granted unlimited powers or functions that can not be delegated by law;
• no powers of expenditure and control are delegated to each subject;
• the contents of the proxies conform to the responsibilities assigned and not overlapping or conflict, even partial or potential, with delegated powers to other parties;
• the powers and attributions conferred are known by the Supervisory Body.
The proxies may also be assigned to persons external to the Company, for example in the context of consultancy relationships. In this case, together with the acceptance of the delegated functions or tasks, these subjects must accept the principles set out in this Code.
3.3 Protection of the share capital and other obligations in relation to the administration
The directors (or whoever carries out their functions) collaborate so that the auditors can carry out the control activities entrusted to them.
In the correct management of the corporate assets, the directors, employees, managers, collaborators and members must:
• correctly assess the company assets, assets, credits and shares, not attributing to them values ​​higher or lower than those due;
• follow the same criteria in the valuations and other operations necessary / instrumental for mergers or demergers with other companies;
• not carry out illicit operations on the share capital.

No one should try to influence the smooth running of corporate assemblies, misleading or in error.
The directors must inform their behavior in good faith and fairness, and in particular are required to:
• carry out their duties diligently and in compliance with the criteria of collaboration with the other corporate bodies;
• promptly notify the Supervisory Body of any behavior that appears to be in contrast even if only potential with the legislative provisions, protecting the integrity of the company assets and disregarding, where required, the interest of the shareholders in restitution of contributions;
• check the balance sheet of the Company, especially with reference to the accuracy and veracity of the data contained therein, before proceeding with the allocation of profits and reserves.
3.4 Custody and management of social assets
C.S.O. endeavors to ensure that the use of available resources, carried out in compliance with current legislation and the contents of the bylaws, and in line with the principles of this Code of Conduct 231, is aimed at guaranteeing, increasing and strengthening corporate assets, to protect Company itself, shareholders, creditors and the market.
The directors, employees, managers and collaborators of C.S.O. they are directly and personally responsible for the protection and legitimate use of the goods (tangible and intangible) and the resources entrusted to them for carrying out their functions.
None of the property owned by C.S.O. may be used for purposes other than those indicated by the same or for illegal purposes.
Every asset owned by C.S.O. it must be recorded in the accounting records, unless the law permits otherwise.
3.5 Duty of impartiality and conflict of interests
All must work impartially and make decisions with rigor and transparency in the conduct of all corporate proceedings, rejecting any unlawful pressure.
In the event that you are subjected to pressures, flattery or requests for favors concerning one's work or the other's work or you receive proposals that tend to make the duty of impartiality disappear, it is expressly obliged to inform without delay the Vigilance. All employees, managers, directors, statutory auditors and collaborators must avoid situations in which any conflict of interest can arise between personal and family economic activities and the duties held within the Company.
The choices and actions must be oriented to the best possible advantage for the Company, which establishes the following rules for this purpose:
• those who have a competing interest, even if only partially, with that of the Company, can not do or collaborate in transactions, through which the assets belonging to or managed by the same are available;
• it is not permitted to carry out business or other professional activity that also partially or indirectly contributes to the interests of the Company.
3.6 Management of payments
The payments related to any transaction in which C.S.O. it is a part that can not take place by means of cash or passport or bank deposit books or bearer securities, when the value to be transferred is in excess of the limits established by the law.


The health, the safety of its employees and the protection of the environment are primary needs that C.S.O. safeguards, respecting the principles of sustainable development and applicable legislation. To this end, the Company plans its activities by seeking a continuous balance between economic initiatives and social and environmental needs and spreads the culture of safety, risk prevention and environmental protection to all stakeholders.
C.S.O. carefully assess all those situations that can generate environmental impacts such as emissions into the atmosphere, waste, noise pollution. It guarantees the safety, the health of its employees and collaborators and the protection of the environment. It ensures full compliance with current legislation on the subject, ensuring a safe and healthy working environment suitable for the performance of work.
C.S.O.'s employees, as part of their duties, must participate in the process of risk prevention, environmental protection and protection of health and safety towards themselves, their colleagues and third parties.
In pursuing the aforementioned objectives, the Company allocates the organizational, instrumental and economic resources with the aim of guaranteeing full compliance with the current accident prevention regulations and the continuous improvement of the health and safety of workers at the workplace and of the related prevention measures. .
The Recipients, each for their own responsibility, are required to ensure full compliance with the applicable laws, the principles of this Code, protocols and company procedures and any other provision required to ensure the protection of safety, health and hygiene on the workplace.
C.S.O. acts in full compliance with current environmental regulations. The discharge and the immissions in the air, in the ground and in the subsoil as well as the disposal of the waste also special and / or dangerous respect, in addition to the laws in matter, the highest quality standards. Where, for the purposes of fulfilling the aforementioned obligations, the intervention of authorized parties is necessary, the latter are chosen from among those with the highest standards of reliability, professionalism and ethics.


Relations with the press, the media and information and, more generally, communication with the outside world, are inspired by principles of truth, correctness, transparency, prudence, and must be kept only by subjects with specific delegation.
All those who work for any reason on behalf of C.S.O. they are required to maintain the utmost confidentiality, and therefore not to disclose or request unduly information, on documents, on know-how, on projects, on company operations and, in general, on what they have learned in the course of their work.
It is not permitted to disclose to third parties to the Company contents, effects, terms or areas of application of measures or determinations having external effectiveness, before they have been formalized and formally communicated to the interested parties. It is not allowed to make statements, statements or statements to the public that can in any way damage or put in a bad light the position and the work of the Company.
Third parties' access to documents internal to the Company is not allowed, both formalized and in the drafting phase, except in the cases and in the manner provided for by the legislation, as well as by the internal regulations in force.
C.S.O. to safeguard its image and the correctness of the information released, and in line with the principles outlined above, it establishes that no employee and / or collaborator - if not authorized - can issue interviews or any type of declaration, on behalf or concerning the Company to individuals external non-qualified journalists. Anyone who is asked to make statements regarding the Company, to external non-qualified persons or accredited journalists, must refer these to the bodies in charge or authorized.


C.S.O. repudiates anyone through violence, threat, deceit, abuse of a situation of physical or psychological inferiority or a situation of necessity or through the promise or the giving of sums of money or other advantages exercised over a person, powers corresponding to those of property right or anyone who reduces or maintains a person in a state of continuous subjection. In particular, C.S.O .:
• does not disseminate, distribute, disclose or publicize child pornography in any way, by any means even by electronic means, or disclose information or information aimed at the lure or sexual exploitation of children;
• does not use labor at low cost through the work of immigrants, even minors, from disadvantaged countries or in conditions of not being able to refuse such employment.
Under the current regulations, C.S.O. undertakes to adopt the most appropriate control and supervision measures in order to prevent any possible behavior aimed at the commission of crimes against the person also requires compliance with the aforementioned legislation, the internal provisions issued and the deontological principles adopted.


C.S.O. in carrying out its business, it operates lawfully and correctly by collaborating with the Judicial Authority, the Law Enforcement and any Public Official who has powers of inspection and carries out investigations against him.
To this end, it requires that all its directors, managers, employees and collaborators provide maximum availability and collaboration towards anyone who comes to carry out inspections and controls on behalf of INPS, the Ministry of Labor and any other Public Administration.
In anticipation of a judicial proceeding, an investigation or an inspection by the PA, no one must destroy or alter records, minutes, accounting records and any type of document, lying or making false statements to the competent authorities; attempt to persuade someone else to provide false or misleading information to the competent authorities.
No one can undertake economic activities, confer professional appointments, give or promise gifts, money or other benefits, to those who carry out the inspections and inspections or to the competent judicial authorities.
Anyone personally or for events dependent on the employment relationship, receives subpoenas, notification of judicial orders, must immediately contact the Company's lawyers and inform the Supervisory Body.


C.S.O. aware of the continuous changes in technology and the high operational, organizational and financial commitment required at all levels of the company structure, it has set as its objective the adoption of effective information security policies; in particular, this security is pursued through (i) the protection of systems and information from potential attacks and (ii) the guarantee of maximum continuity of service.
Under the aforementioned rules, it is forbidden for anyone to:
a) to alter IT documents, public or private, having evidential value;
b) illegally access the IT or electronic system of public or private subjects;
c) to illegally access their IT or telematic system in order to alter and / or delete data and / or information;
d) to hold and misuse codes, keywords or other means suitable for access to an IT or telecommunications system of competitors, public or private, in order to acquire confidential information;
e) abusively detaining and using codes, keywords or other means suitable for access to its IT or telematic system in order to acquire confidential information;
f) carry out activities of procurement and / or production and / or diffusion of equipment and / or software for the purpose of damaging an IT or telecommunications system, of subjects, public or private, the information, data or programs contained therein, or to favor the interruption, total or partial, or the alteration of its operation;
g) carry out fraudulent activities of interception, prevention or interruption of communications relating to an IT or electronic system of public or private subjects, in order to acquire confidential information;
h) install equipment for the interception, prevention or interruption of communications by public or private subjects;
i) carry out activities of modification and / or cancellation of data, information or programs of private subjects or public entities or in any case of public utility;
j) carry out activities that damage information, data and computer programs or other people's programs;
k) to destroy, damage or render usable IT or telematic systems of public utility.
C.S.O. it deals with the information it possesses in full compliance with the regulations in force in the countries in which the Company operates and within the limits established by the Code. The information is used exclusively for permitted purposes and is in any case treated ensuring maximum confidentiality.


C.S.O. condemns any behavior that may even indirectly facilitate the implementation of criminal offenses such as the receiving, laundering or use of money, assets or other benefits of illicit origin; to this end, the Company undertakes to activate all the preventive and subsequent control procedures necessary for the purpose.


C.S.O. inspires its conduct towards competitors to the principles of loyalty and fairness and, consequently, stigmatizes any conduct that may constitute impediment or disturbance to the operation of an enterprise or a trade or that may be in any way connected to the commission of crimes against industry and commerce.
In particular, all Recipients are expressly prohibited from:
a) use violence on things or use fraudulent means to hinder the industrial or commercial activity of others;
b) carrying out, in the exercise of an industrial, commercial or otherwise productive activity, acts of competition using violence or threats;
c) perpetrate behaviors suitable to cause damage to national industries by placing on sale or otherwise putting into circulation, on domestic or foreign markets, industrial products with names, brands or distinctive signs counterfeited or altered;
d) deliver to the purchaser, in the context and / or in the exercise of a commercial activity or of a shop open to the public, one mobile thing for another (aliud pro alio) or a mobile thing which, by origin, origin , quality or quantity is different from that declared or agreed;
e) sell or otherwise put in circulation intellectual property or industrial products bearing names, brands or distinctive signs - national or foreign - capable of misleading the buyer on the origin, provenance or quality of the works themselves or of the product;
f) manufacture or use industrially objects or other goods made by usurping or violating the title of industrial property, while being aware of the existence of the same, as well as trying to profit from the above mentioned goods by introducing them in the territory of the State, holding them and / or placing them for sale or putting them in circulation anyway.
C.S.O. it also undertakes not to engage in illicit or otherwise unfair behavior in order to obtain commercial secrets, supplier lists, or information relating to infrastructure or other aspects of the economic activity of third parties. C.S.O. furthermore, it does not hire employees from competing companies in order to obtain confidential information, nor does it induce the personnel or customers of competing companies to disclose information that they can not disclose.


C.S.O. condemns any behavior by anyone involved in altering the correctness and veracity of the data and information contained in financial statements, reports or other corporate communications, addressed to shareholders, the public and the company carrying out the legal audit.
All the subjects called to the formation of the aforesaid deeds are obliged to verify, with due diligence, the correctness of the data and information that will be then implemented for the preparation of the above mentioned deeds.
C.S.O. condemns any action also against private parties consisting in promising or offering, directly or indirectly, money, services, services or other benefits from which an undue or unlawful interest or advantage may arise. Gifts or other utilities of modest value and, in any case, included in the legitimate uses, customs or activities are allowed.
C.S.O. requires that the directors, function managers and employees of the company, take proper and transparent conduct in the performance of their duties, especially in relation to any request made by the shareholders, the board of statutory auditors, the corporate bodies and the company legal audit in the exercise of their respective institutional functions.
It is forbidden to carry out any behavior on the part of the directors of the company, aimed at causing damage to the integrity of the company's assets.
It is forbidden to carry out operations of reductions or share capital or mergers with other companies or demergers in order to cause damage to creditors.
It is forbidden to carry out any act, simulated or fraudulent, aimed at influencing the will of the members of the company to obtain the irregular formation of a majority and / or a deliberation different from that which would otherwise have been assumed.
It is forbidden to spread false information both inside and outside the Company, concerning the company itself, its employees, collaborators and third parties working for it.
In the event of verification and inspection by the competent public authorities, the Recipients must maintain an attitude of maximum availability and collaboration towards the inspection and inspection bodies.
It is forbidden to hinder, in any way, the functions of the public supervisory authorities due to their institutional functions.


C.S.O. condemns any behavior, both of those who play a pivotal role within the Company, which may even indirectly facilitate the implementation of criminal offenses, having national or transnational character, such as criminal association, and among these also the one aimed at illicit trafficking in narcotic or psychotropic substances, the recycling of assets, money or other benefits of illicit origin and the obstruction of justice, or to determine possible violations of the provisions against organized crime in force. To this end, the Company undertakes to activate all methods of preventive and subsequent control necessary for the purpose (separation of roles, traceability of operations, monitoring, etc.).


Confidential information concerning data, strategies and corporate objectives must not be acquired and disclosed to outsiders to the C.S.O. if not by the expressly responsible and delegated to this task.
Information regarding the products, their development, production processes, strategies and commercial conditions, customers, partnerships, scientific, technological and industrial know-how, financial transactions, operating results, investments, projects and technical documentation, marketing plans, lists of suppliers and purchase prices, logistical aspects, IT solutions and anything else that is part of the corporate knowledge to manage and the development of the CSO business.
The confidential information and materials that the Recipients use in their work activities, are the exclusive property of C.S.O., which protects the confidentiality and claims its origin.
The C.S.O. Company undertakes to protect the information, always complying with the provisions imposed by the privacy law and avoiding improper use.
Each Recipient is directly and personally responsible for the care, protection, efficiency, conservation of intangible assets (copyrights, patents, trademarks and identification marks) entrusted to him by the Company to carry out their duties, as well as their use in their own way. and in compliance with the corporate interest. The use and use for personal purposes of the intangible assets entrusted to the Recipients for carrying out their professional duties is prohibited.

Patents, copyrights, trademarks, commercial information and industrial secrets known as company know-how, are assets of the C.S.O. and, therefore, C.S.O. itself, is careful to ensure the respect of their own and others' intellectual property through the express prohibition of the use of these resources if not in full compliance with the applicable law, policies and procedures envisaged for their protection. It is therefore absolutely contrary to the policies of the C.S.O. unauthorized reproduction of software, documentation or other materials protected by copyright. In particular, the Company respects the restrictions specified in the license agreements related to the production / distribution of third party products, or those stipulated with its software suppliers and prohibits the use or reproduction of software or documentation outside as permitted by each of these license agreements. The Company prohibits any behavior aimed at determining the loss, theft, unauthorized disclosure or improper use of its own or other people's intellectual property or of confidential information. To this end, C.S.O. undertakes to activate all the preventive and subsequent control procedures necessary for the purpose, ensuring compliance with copyright legislation, in particular in the management of scientific works and databases, as well as the protection of recognition marks, such as trademarks and patents. The C.S.O. therefore stigmatises the use of databases (extraction, reproduction of data, public presentation, etc.) for purposes other than those for which they were established and, in any case, contrary to what is permitted by the law on the protection of author or use of software not expressly authorized or without license or illicit origin. To this end, it is expressly forbidden to use IT resources for purposes other than those permitted by corporate security policies or to carry out unlawful conduct.
The disclosure to third parties of experimental data, design results in progress and not yet protected by patent, patent applications that are not yet public, in the period of secrecy after filing, must be protected by secrecy agreements between the parties. It is also a violation, the disclosure of information defined as secret, such as the anticipation of results of experimental studies not yet protected during presentations at conferences or fairs.


It is absolutely forbidden to assume towards the person called to make statements before the Judicial Authority, in the context of a criminal proceeding and having the right not to respond, conduct aimed at influencing or influencing him in the context of his statements; and is therefore required to those who interact with the subject (ie decisions on the evaluation of the performance or on the awarding of prizes, or on the imposition of disciplinary sanctions, etc.), in order to safeguard the principle of independence and autonomy of the same in expressing itself before the Judicial Authority.


C.S.O. condemns and opposes the use of Company resources for the financing and fulfillment of any activity aimed at achieving terrorist objectives or subversion of the democratic order, and also requires compliance with the aforementioned legislation, internal provisions issued and of the deontological principles adopted.


It is forbidden to falsify, hold, spend or otherwise put into circulation banknotes, coins, public credit cards, revenue stamps and instruments and identification marks that are counterfeited or altered.

C.S.O. considers the principles of integrity, transparency and legality in relations between its operators and third parties to be mandatory principles, especially in the event that one or the other holds the status of Public Official and / or in charge of a public service.
In consideration of the above, all recipients of this Code of Ethics must adopt the following behaviors:
1) nobody must offer or promise money or other benefits not due to a Public Official or to a public service representative who has the qualities of a public employee, to induce him to perform an act of his office;
2) nobody must offer or promise money or other benefits not due to a Public Official or a public service representative to induce him to omit or delay an act of his office, or to act contrary to his duties;
3) no one, in the context of judicial proceedings, can promise or lead to promise of utility or instigate corruption;
4) no one can induce improperly to give or promise benefits in relations with a Public Official or in charge of public service or instigate corruption;
5) all company operators that for any reason receive requests from a Public Official or public service representative regarding the above, must promptly report the request to the General Management, as well as any requests for instigation received from other company operators;
6) anyone who can, for any reason, hold the status of Public Official or public service officer:
- may misuse his qualification or his powers to force or induce anyone to give or promise to him or a third party money or other benefits;
- can ask or receive for himself or for a third party a salary that is not due to him (in cash or other benefits) or even accept the promise to perform an act of his office;
- may omit or delay an act of his office or perform an act contrary to the duties of the office;
- can ask or receive for himself or a third party a salary that is not due to him to favor or damage a party in a civil, criminal or administrative trial.
The above provisions apply to all those subjects that deal with the Public Administration in any way, or with subjects having the status of Public Official or person in charge of public service, as well as to all operators who, for the type of functions performed , assume the status of public official or public service representative.


18.1 Reports of violations of the Code
Anyone who becomes aware of violations of the 231 Code of Conduct and, in general, of internal procedures and regulations, is obliged to promptly inform the Supervisory Body. Anonymous reports will not be considered. It is guaranteed to anyone who wants to appeal to the Supervisory Body the anonymity and the utmost confidentiality in the processing of the information received in compliance with the Privacy law.
18.2 The sanctioning system
The violation of the principles established in this Code compromises the fiduciary relationship between C.S.O. and its directors, employees, managers, consultants, collaborators, customers, suppliers, partners and anyone who, in various capacities, has relations with the Company.
It follows that any transgressor of the individual rules of conduct prescribed by this Code of Conduct 231 will be punishable by disciplinary sanctions that may also involve the termination of the employment relationship or the collaboration contract. C.S.O. will pursue the violations of this Code through appropriate and proportionate disciplinary measures, commensurate with the gravity of the infringement and its possible repetition.
The application of disciplinary sanctions for violation of the rules of conduct and failure to comply with the company provisions is independent of the establishment of legal actions and their outcome, and therefore regardless of the nature of the criminal offense that the conduct may configure.
The disciplinary system adopted by C.S.O., in line with the provisions of the Civil Code, the Workers' Statute and the applicable National Collective Labor Agreements, can be consulted at the Personnel Department.

The knowledge and observance of the Code by all its recipients are primary conditions for the transparency and image of the Company.
To this end, copies of this Code will be available at the registered office and in any case at the Personal Area.




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