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Ethical code

Initial assumption

EGO International Srl was born in 2002 thanks to the will of the founding partners, with the goal to give life to a company that could export Made in Italy in the world. In 2015, EGO becomes EGO International Group Srl (hereinafeter “EGO International” or “Company“), same identity but an even more solid and competitive group

EGO International’s purpose is to bring together the requests of the international buyers with the offer of the italian companies, providing concrete business opportunities.

EGO International daily invests on expertise, research and know-how, in order to give customers the best services to increase their turnover.

Purpose of the Self-Discipline Ethical Code

In application of the european and domestic legislation, EGO International adopts this Ethical Code in order to promote and expand a system of ethical values and behavioural rules among employees, collaborators, consultants and agents, as well as to encourage a moral and professional conduct, in line with the current regulations.

Disciplinary actions will be implemented in case of violation, in proportion to the infringement’s seriousness. EGO International also assumes the committment, by using and expanding this ethical code, to create and preserve a cultural context based on trust, where no abuse is tolerated.

The Ehtical Code is based on principles of honesty, professionalism, care and respect for the Customer, integrity and impartiality, as well as on the highest stardards in crime prevention, such as, as an example, money laundering and corruption.

Subjects to whom it is addressed

Sales agents, employees, collaborators, consultants and anyone having mandate for operating on behalf of EGO International, both in Italy or abroad.

Ethical principles and values

Legality

EGO International assumes the full respect of laws and regulations in each of the countries where it operates, as essential founding principle of its corporate activity.  All the company guidelines, issued and to be issued, are conformed to them.

All the recipients of the present code are committed to observe the existing laws and regulations. In no event the compliance of actions made in the interest of the company can justify an improper, unfair or illegal conduct, contrary to laws, regulations or the presente Ethical Code, sucha a conduct would lead to the application of sanctions by EGO International.

Impartiality

In taking any decision, EGO International rejects, fights and penalizes any behaviour even potentially discriminatory with respect to race, sex, religion, age, political or syndacate-related opionions, personal or social condition.

Transparency

EGO International assumes its decisions and conducts its business in full transparency. The Company provides any information required by the law with clarity, completeness and punctuality, and it bases its relations with counterparts on the principles of collaboration, accessibility and conformity to the given informations.

Privacy

EGO International guarantees the non-disclosure of the non-public information in its possession, and it avoids to collect and process personal datas, except in case of aware authorization given by the parties concerned.

EGO’s data processing is carried out in accordance to the current regulations.

Anyone that, in the name or behalf of EGO International, processes the collected datas for commercial or ordinary management purposes, is bound to the strictest discretion, to guard and manage the information written on magnetic or paper supports in accordance to the laws and  the internal procedures, and not to disclose such information, except in case of explicit approval by the person concerned.

Good faith, loyalty and honesty in the business performance

In the practice of its corporate activity EGO International safeguards and promotes the principles of god faith, loyalty anad honesty, which are the base of any company behaviour  according to the present document.

In carrying out the assigned tasks, every employee or collaborator is bound to cooperate actively and faithfully with colleagues, collaborators or hirarchic supervisors, to mantain a respectful attitude, to accurately perform the received tasks and to cooperate with the verification operation carried out by internal control advisors or assigned consultants.

The enactment of the internal rules and the decisions concerning the company strategies are based on the respect of the above principles.

Professionalism

EGO International is committed to guarantee the production of quality services.

The social object is realized exclusively through the excellence of the provided services, in terms of quality, transparency and competitiveness, focus on the customer and technical and technological innovation.

The activitiers performed to this end are guided by the pursuit of efficiency and effectiveness of the company processes, through a rational use of resources.

The business goals are regularly communicated and shared with all the operational areas, and the Company takes is responsible for identifying and monitoring the risks that may impede the achievements.

In order to ensure coherence of the activity with the above principles, EGO International work so that every operation or transaction is properly authorized, recorded, verifiable and traceable

Rules of Conduct in the company activity

Duties in chief to Employees, Agents and Collaborators

Through their behaviors, EGO’s employees, collaborators and agents are kept to: protect the corporate image and respectability, ensure the organization and management of their tasks in accordance to the laws and the instructions received, always inspire their actions to principles of honesty, fairness, faithfulness and good faith, avoid conflicts of interest, not to accept external professional tasks that may interfere with the activities performed in the name or behalf of EGO International.

Customer relations

EGO International is engaged to set professionalism, fairness, clarity, courtesy and care as characterizing elements of the relationships with the customers, with the purpose to fully sattisfy their needs. To this end, and with the goal to consolidate over time an ongoing trust relationship, the relation with customers must be characterized by fairness, transparency and confidentiality. In the case of improper conducts or behaviours by the agents or collaborators, detected by EGO International during the negotiations or the contractual phase, that are contrary to the principles of the present Ethical Code, EGO International will immediately terminate the relationship.

EGO International is committed to propose clear and transparent contracts, containing essential and precise information, avoiding the use of difficult to understand or ambiguous clauses. Furthermore, the Company gives customers any helpful information for the proper and timely exsercise of the rights they are entitled to.

Employees, collaborators and agents, in the context of the covered subjects and the specific areas of expertise, are bound to comply with the principles of clarity, transparency and good faith in the relationship with EGO International’s potential or consolidated customers.

Information system

EGO International, in order to implement the proper use of the informaton system, operates so that: no unauthorized modification is made to the computer system, the rules aimed to regulate the pourchase of hardware and software are respected, and such instruments are introduced in compliance to law requirements and the company rules, the operation continuity is guarantee; the datas, informations and technologies managed by the Company, are guarded with physicial and logical security systems, aimed to prevent the loss and the unauthorized alteration of datas or programs.

For the proper use of the information system, EGO International arranges as follows:

All work tools, with particular reference to the information ones, must be used exclusively for the working activity.

It is prohibited to each recipient of this Ethical Code in the exercise of the working tasks, to enter without authorization, by using informatic or telematic technologies, to information systems that are external to the Company or to alter, in any way the operation of datas, informations or programs therein contained and/or modify illegitimately the information in order to gain an undue advantage for himself, for the Company or third parties.

In absence of explicit written permission, it is prohibited the reprodutcion, the copy or transmission outside the Company of any document or material located in the Company’s server or the ones used by it. It is , however, strictly forbidden to duplicate or retain unauthorized copies of the Company’s softwares, or the ones put at disposal of the users, as well as to install unauthorized softwares in the user’s computers.

Protection of the privacy of personal datas

EGO International guarantees that the processing of the datas provided by employees, collaborators, agents, consultants, suppliers, customers or third parties, is made in compliance with the current laws, and they will not be communicated or discloses without the prior permission of the subject, except for legal obligations.

Any information or document regarding EGO International or its Directors, Employees, Customers, Agents, Consultants, Suppliers, Commercial or Industrial Partners is considered confidential. Regardless of the mode of delivery, transmission or storage, and of the kind of used support (magnetic, electronic, paper, ecc.)

The personal datas processed by the Executive Employees, must be: processed lawfully and fairly, collected and recorded for specifical, explicit, legitimate, precise, updated and relevant purposes, that do not exceed the purposes for which they have been recorded and processed; and preserved in a form that allows the identification by the concerned person for a period that does not exceed the necessary one for the collection purposes.

It is remarked that the datas processed in violation of the current laws cannot be used.

The subjects in charge of those activities must take the proper measures to avoid the risks of destruction and loss, even accidental, of the above-mentioned personal datas, as well as the access risks by unauthorized subjects and the risks coming from a improper use non-compliant to the collections purposes.

Monitoring of the application of the Ethical Code, disciplinary system and sanctions

Surveillance

In order to ensure the full and effective application of the Ethical Code, EGO International will appoint and independent Supervisory Body for implementing and updating the Ethical Code, having the following tasks:

  • promoting awareness regarding the Ethical Code and ensure the internal and external dissemination of the contents
  • guaranteeing the update of the Ethical Code contents in compliance with the need induced by the evolution of the organization and the tools used for the achievement
  • identifying tools and procedures aimed to reduce the risk of violation of the Ethical Code
  • monitoring the application of the Ethical Code by the concerned subjects through direct verification
  • receiving internal and external reports regarding situations of non-compliance of the Ethical Code, carrying out the necessary detection, as well as instructing the disciplinary proceeding aimed to punish the violations of the Ethical Code’s principles

The reports and information acquired by the surveillance organ operating as Supervisory Body for the implementation and update of the Ethical Code are considered confidential and cannot be disclosed, except when required by law.

Disciplinary proceedings and sacntions for employees

The non-compliance or violation of the behavioural rules imposed by the Ethical Code or the internal procedures byt he employees, represents a breach of the duties deriving by the employment relationship ex. art 2104 c.c and disciplinary offense.

The compliance to the present Ethical Code is part of the contracutal obligations committed by the employees, also ex art. 2104 c.c., when signing the employment contract. The violation gives rise to the application of disciplinary sanctions pursuant to art. 2106 c.c. in accordance with the law, also for the entity of the sanctions, and to the Regulations for the employees of Confindustria in force at the time event, also according to the procedures of the art. 7 of the Worker’s Statute

The National Collective Labour Contract is the complementary tool for the management of the company activity. The rules of the National Collective Labour Contract must be applied in the different situations covered in the contract.

In particular, disciplinary maasures will be applied acoording to the National Labour Contract.

The sanctions will be applied in accordance to the significance of the individual cases and will be proportioned to seriousness.

The detection of the above-mentioned infringements, the management of the disciplinary proceeding as well as the implementation of the assigned sanctions.

Disciplinary proceeding and sanctions for Executives, Administrators and Auditors.

In case of violations of the internal procedures by the Executives and the Ethical Code, EGO International will evaluate the events and the behaviours and will take appropriate measures against the responsibles, given that these violations represent a breach of the obligations deriving by the employment relationship ex art. 2104 c.c.

In case of violation of the Ethical Code by the Administratorss or Auditors, the advisory body operating as “Supervisory Board for the implementation and update of the Ethical Code” will inform the Management Board and the Board of Auditors, that will adopt the most appropriate actions in accordance to law.

The compliace with the provisions ot this Ethical Code is part of the obligations committed by the Administrators when accepting the charge. The violation of these provisions may be a basis for the action against the responsible Administrator according to the current provisions of law.

Disciplinary proccedings and sanctions for agents, consultant, external collaborators and third parties.

Any behaviour by agents, consultants, external collaborators, and third parties operating, in accordance to contracutal relations of non-employed work, for EGO International, that si contrary or in violation of the Ethical Code will bring about, according to specific contract clauses, the termination of the contract, except an additional compensation claim in case this behaviour has brought damages for EGO International, even independently by the contract’s termination.

Il rispetto delle disposizioni del presente Codice Etico rientra fra le obbligazioni contrattuali assunte e la loro violazione potrà comportare, a seconda della gravità delle violazioni, ovvero della loro reiterazione, l’applicazione degli artt. 1454 c.c. “Diffida ad adempiere” e 1453 c.c. “Risoluzione del rapporto contrattuale per inadempimento”.

The compliance to the provisions of the present Ethical Code is part of the committed obligations and their violation will lead, depending on the seriousness of the violations and their recurrence, to the application of the art. 1454 c.c “wary to act” and 1453 c.c. “Terminatin of the contract for non-fulfillment”.

Final provisions

The present Ethical Code, as well as its periodic modifications and integrations, has been approved by EGO International’s Management Board, and is into force since its first delivery inside the Company, that took place on June 15th 2015, and the modification of October 9th 2015.

Each recipient is obliged, not only to show an attitude to compliance, but also to mantain an exemplary conduct with regard to the adherence to rules and principles set out in the present document.

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