Pag. 1 / 5 C O D E OF E T H I C S Letter from the Managing Director! " #$%$$&!' ( Index: a) Introduction and objectives b) Addressees and application area c) General principles d) Treatment of data and information e) Protection of company assets and withholding of information f) Protection of workers rights and dignity g) Protection of the workplace h) Environmental protection i) Relationships with external authorities j) Internal control system and sanction system k) Value of the Code of Ethics Rev. Date Note Approved 0 30-05-2007 OdG
Pag. 2 / 5 a) Introduction and objectives With this Code, MAPRO intends to formally state that which has always been its line of behaviour towards bearers of interest. Its shareholders and the Governing Body (Directors and Management) therefore wish to make this Code public, by putting into writing its rules on behaviour in civil and economic contexts, with the objective of affirming MAPRO s credibility and the transparency of the behaviour of all personnel working at MAPRO and collaborating with MAPRO. b) Addressees and application area The Code of Ethics is addressed to the Administrative Body and all MAPRO employees, and also includes those who operate and work with MAPRO on both long-term and short-term status. The Code defines the rules of behaviour which must be respected during the execution of professional activities and represents the guidelines to be followed in relationships with colleagues and contacts with clients, suppliers, with other companies, with public offices and authorities, with political and union organisations and with information structures. The Code of Ethics integrates the Organisational Model adopted by MAPRO, following the guidelines indicated in Legislative Decree 231/2001 for the prevention of unlawful action considered herewith. The Governing Body pledges to spread the Code to all interested parties and to provide all necessary means to facilitate its full implementation. c) General principles Relationships and behavioural practices, at all company levels, must be founded on principles of honesty, fairness, transparency, privacy, impartiality, diligence, loyalty, teamwork and mutual respect. Managers must work towards company growth according to the objectives of Shareholders and this growth must be sustainable as regards economic and financial capacity, and always respecting the bearers of interest. Addressees must avoid activity which could constitute a conflict of interest with MAPRO or which could interfere with the ability to make decisions in line with the company objectives. In particular, all interested parties shall: - avoid situations in which personal gain could give rise to a conflict of interest with that of MAPRO and to refrain from following personal interests which are in contrast with the interests of MAPRO; - not use, for their own ends or for those of a third party, directly or indirectly, any business opportunity destined for MAPRO;
Pag. 3 / 5 - not accept donations, favours or any type of asset except for gifts and acts of business courtesy of moderate value provided these are not intended to secure advantages of an improper nature; - not give donations in cash or goods, with the exception of gifts and acts of business courtesy of moderate value; - not negotiate deals in competition with MAPRO; - operate according to the law in relationships with third parties, and according to the rules of conduct given in this Code, to its norms and internal procedure; - not effect corruptive practices towards public officials and civil servants; - not state a falsehood in order to obtain public funds, even if this should benefit MAPRO; - not use information obtained during the execution of its own corporate roles with the intention of procuring benefits directly or indirectly, and avoid all improper and unauthorised use of said information; - not put into act any behaviour which may benefit competitors and rival companies - not operate within the MAPRO environment with the aim of accessing and/or receiving paedophilic-pornographic material, or entering into gambling activities. d) Treatment of data and information Based on respecting the current norms in force as regards protection and treatment of personal data, addressees of the Code shall assure that confidential information be used solely for purposes in connection with the executing of its own professional requirements, and shall endeavour to protect information in MAPRO s possession, avoiding all improper or unauthorised use. In order to achieve this objective, MAPRO is equipped with the Document of Security Programming for personal data in MAPRO s possession. e) Protection of company assets and withholding of information Every addressee is responsible for the protection and safekeeping of MAPRO assets, tangible and intangible, obtained in trust for the execution of its own duties, and also for using them in strict accordance with corporate purposes. The information found in periodical reports and in accounting books, both general as well as detailed, must keep to principles of transparency, fairness, completeness and accuracy. With this aim, every addressee is obliged to co-operate towards a correct representation of company activities. Should addresses discover omissions, falsifications, carelessness in terms of information and documentation, they must refer such cases to the attention of the Governing Body, be it through their own officer in charge, if an employee, or through their own company consultant, if external.
Pag. 4 / 5 Information, documents and data can only be received from or communicated by people who hold general authorisation, owing either to their position in the company or their professional duties, that is to say by people who are specifically appointed. f) Protection of workers rights and dignity Every addressee, in his professional field, must endeavour to foster a working environment which is free from prejudice and which operates respecting the personality of individuals; he shall therefore take an active role in maintaining an internal climate which guarantees respect for the dignity of everyone. Relationships among MAPRO employees are founded on the values of civil living and proceed respecting the rights and freedom of people and the fundamental principles which affirm equal social dignity without discrimination against nationality, language, sex, religion or political and union membership. Relationships among employees, regardless of their levels of responsibility, shall proceed with loyalty, fairness and respect, without detriment to the differing roles and professional functions. Every manager must exercise the powers associated with his position applying objectivity and common sense, attending to the professional development of his staff and the improvement of working conditions. Every employee must be co-operative, executing his duties with responsibility, efficiency and diligence. g) Protection of the workplace Complying with current legislation, MAPRO endeavours to provide an adequate working environment for the safety and health of its employees. The addressees shall commit themselves to respecting the measures of prevention and safety in place, and to promptly signal any shortcomings to the person responsible. h) Environmental protection MAPRO is, without detriment to the applicable norms, committed to adopting all measures aimed at reducing its impact on the environment and strives to raise awareness and respect on the part of all its personnel. i) Relationships with external authorities Relationships with institutions, public administrative offices, authorities, associations, political and union organisations, information structures, are inspired by principles of fairness, impartiality and independence and these relationships are the domain of the competent company offices. In relationships with customers and suppliers, every addressee represents MAPRO and therefore must follow the general objectives as defined by the Governing Body.
Pag. 5 / 5 j) Internal control system and sanction system The internal control system contributes towards guaranteeing the respect of laws, internal procedures, strategies and company policies, to achieving the set objectives, to the protection of tangible and intangible assets, to the running of the company in compliance with the criteria of efficacy and efficiency, and also to the reliability of accounting and administrative data within and outside MAPRO. The responsibility of ensuring a correct performance of the internal control system is placed on all addressees of this Code, according to the duties they carry out. Each employee is obliged to promptly inform his direct officer in charge or the Governing Body, of the onset of actions which could interfere with the correct running of professional operations. k) Values of the Code of Ethics Without prejudice to the possibility of MAPRO having to recover damages which may derive from behaviour that does not conform to the Model of Prevention of Unlawful behaviour and therefore the Code of Ethics, any non-compliance with the norms contained in these will, in the case of employees, bring about disciplinary sanctions as provided for in current law and contractual regulations; in the case of consultants, as provided for in the relative position and contract; for components in social organisations, the Board of Directors decides the disciplinary measures to take in consideration of the gravity of the offence.