Our Code of Ethics

Toro Investigazioni e Sicurezza Srl aims to identify and establish in this document the rights, duties, responsibilities, and the principles of fairness, honesty, integrity, and transparency of conduct, the way of working and conducting relations both internally and with third parties.

All managers, employees and collaborators of the Company, as well as external collaborators acting in the name or on behalf of the company are required to acknowledge and comply with this code. The Code of Ethics is brought to the attention of all those with whom the company has business relationships (clients, suppliers, consultants, etc.).

The company will carefully supervise compliance with this Code, the transparency of conduct intervening with the sanctions provided for in the Civil Code and the Criminal Code.

2 GENERAL PRINCIPLES

The recipients of this Code of Ethics shall abide by, to the extent of their competence, the following principles:

    • act in full compliance with laws and regulations in force;
    • treat clients, employees, external collaborators, suppliers, the surrounding community and the institutions that represent it, as well as any third parties with which it enters into a relationship for professional reasons with honesty, fairness, impartiality and without prejudice;
    • behave responsibly towards other operators present in the operating context of the Company also protecting personal safety and health and that of third parties;
    • protect personal health and safety and that of third parties;
    • maintain the confidentiality of information concerning the company, its know-how, employees, clients and collaborators.

3 EHTICS OF RELATIONS WITH THIRD PARTIES

3.1 Relations with Clients

The Company, pursuing its success thanks to the professionalism and competence, recognizes the importance of safeguarding the quality of relationships with clients and its continuous improvement. The company takes into account the various needs of its clients, giving them the same importance.

With reference to Legislative Decree 30 June 2003 no. 196, in order to ensure an appropriate level of confidentiality and protection to the processing of personal data, the company oversees the management of the personal data of each client with the utmost attention in particular to the acquisition also informal of news, data and documents marked by a high degree of confidentiality, the exchange of correspondence, especially by electronic means; use and destruction of data on particular devices or media, especially electronic (including audio/video recordings), or documents (in particular, service relationships); to the acquisition of third-party data and documents. The data processing is thus carried out with respect for human rights and fundamental freedoms, the dignity of the party concerned and especially in respect of confidentiality.

The data is processed lawfully and correctly, collected and recorded for specific, legitimate and explicit purposes, not exceeding the purposes for which they were processed

3.2 Relations with Employees

Human resources are an essential factor for the existence, development and success of a business.

For this reason, Gruppo Investigativo – Investigazioni Private e Sicurezza – protects and promotes the value of human resources in order to improve and enhance the wealth and competitiveness of the skills possessed by each collaborator in the organizational context of the company.

Gruppo Investigativo – Investigazioni Private e Sicurezza – provides equal opportunities to all employees on the basis of their professional qualifications and individual skills of each, without any discrimination of religion, race, political or trade union preference or gender.

Therefore, the Company, through the competent department selects, hires, remunerates and organizes employees on the basis of merit and competence.

The work environment, as well as adequate in terms of safety and personal health of employees, promotes mutual cooperation and team spirit while respecting the moral personality of each person, and is free from prejudice, intimidation, illegal conditionings and undue discomfort.

3.3 Relations with Suppliers

The selection of suppliers and the determination of the conditions of purchase must be based on an objective evaluation of the quality, the price of goods and services requested, the ability to provide and timely ensure goods and levels of service adequate to the needs of the Company. In any case, a supplier must not be preferred over another because of personal relationships, favouritism, or benefits other than for the exclusive interest and benefit of the Company.

3.4 Relations with the Public Administration

In dealings with the Public Administration, the company pays special attention to every act, conduct or agreement, so that they are characterized by the utmost transparency, traceability, fairness and legality. In the course of business negotiations, requests or commercial relations with Public Administration, there will be no conduct, directly or indirectly, that correctly influence the decision of the counterparty. In particular, it is not allowed to examine or propose employment and/or commercial opportunities that may benefit employees of the Public Administration in a personal capacity, or solicit or obtain confidential information that may affect the integrity or reputation of both parties. If the company uses a consultant or a third party to represent it in relations with the Public Administration, said subjects and their personnel are subject to the same directives that apply to employees of the company.

3.5 Gifts, favours and benefits

Any form of gift is not allowed that may be interpreted as exceeding normal business practices or courtesy, or aimed at obtaining favourable treatment in conducting any activity connected to Gruppo Investigativo – Investigazioni Private e Sicurezza. In particular, any form of gifts to public officials or their family members, which may influence their independent judgement or induce them to ensure any advantage.

4 PROTECTION OF HEALTH AND SAFETY IN THE WORKPLACE

With reference to Legislative Decree 9 April 2008, no. 81 “Implementation of article 1 of Law 3 August 2007, no. 123, concerning the protection of health and safety at work” published in the Official Gazette no. 101 of 30 April 2008 – Ordinary Supplement no. 108, some articles are examined to supplement the regulations already known.

Basically, there are rules with which both the employer and the employee must comply; this will be discussed further in a subsequent meeting together with an external company that deals with information and training in working entities. The meeting will aim to illustrate PROTECTION MEASURES AND reciprocal OBLIGATIONS.

– prohibition to carry out on its own initiative, any manoeuvres or operations that may endanger their safety, the safety of staff, of the Principal and clients;

– smoking is prohibited during working hours and in all work areas;

– it is absolutely prohibited before and during working hours, to take substances that may alter the physical or mental condition of the person and expose the same to risks resulting from inattention, poor concentration or partial control of oneself and one’s physical and psychological qualities; the use of drugs or alcohol, even occasional, causes alterations in mental and physical balance thus it is prohibited to use alcohol or drugs even before work; workers who perform tasks at risk of their own safety and that of others can be subjected, for reasonable doubt, to periodic medical examinations for verification;

5 MANAGEMENT OF COMPANY INFORMATION AND DOCUMENTATION

5.1 Usage and storage of company information

All information and other materials obtained by the Recipients of this Code of Ethics in relation to their employment or professional relationship is strictly confidential and shall remain the property of the company.

Such information may include current and future activities, including news not yet disclosed, information and announcements even about to be disclosed.

Those who, by virtue of their duties have access to privileged information concerning the company (ex: information on acquisition projects , strategic plans, business strategies, etc.), may not use them to their advantage and/or that of family members, acquaintances, and in general third parties, but only for the performance and within their office or profession.

They shall also pay special attention not to disclose privileged information and prevent any misuse of such information.

Although the information and/or any other kind of news, documents or data that are not in the public domain and are connected to the acts and operations specific to each task or responsibility, shall not be disclosed, nor used and nonetheless communicated for other purposes without specific authorization.

In any case, privacy is recommended for the information concerning the company and business or professional activities.

5.2 Use of I.T. resources

IT and electronic resources represent for the company T.I. and S. a fundamental tool for the competitive growth of the company, ensuring efficient control of the flow of information and control of the activities of the company.

All those who use IT tools are required to adopt diligent conduct consistent with the provisions of article 1176 of the Civil Code. In particular, if company computers or archives are used, those in charge who have access to electronic tools shall however:

  • also adopt the necessary precautions to ensure the secrecy of the confidential component of authentication credentials (ex. password) and the diligent custody of devices held for exclusive use;
  • not leave the electronic instrument unattended and accessible during a processing session (notifying the person in charge by management in the related office regarding temporary non-attendance or disabling access);
  • change the password on first use and then at least every 6 months (3 months in the case of sensitive data);
  • promptly notify the person in charge of safekeeping the password (if identified) of any change to the password.

The person in charge that has access to paper files shall however:

  • perform only processing operations and access paper files strictly within the scope of related duties;
  • control and safe keep documents containing personal information necessary to conduct the related tasks returning them as soon as the necessary operations have been completed;

5.3 Accounting books and Company registers

Gruppo Investigativo – Investigazioni Private e Sicurezza – accurately and completely records all the activities and business operations according to the principles of maximum accounting transparency. Administration and accounting activities are based on efficiency, accuracy, completeness and correspondence with the accounting standards implemented to promote the necessary controls and verifications of legitimacy and consistency of the decision-making and authorization process and performance of business operations and tasks assigned.

Gruppo Investigativo – Investigazioni Private e Sicurezza – believes that the fairness and transparency of company financial statements are important and ensures at all levels the utmost collaboration, providing correct and true information about the business, assets and business operations, as well as regarding any reasonable request received by the competent bodies.

6 COMPANY CONDUCT

Gruppo Investigativo – Investigazioni Private e Sicurezza – believes that it shall always pursue corporate conduct in respect of the formal and substantive rules of law, maintaining transparent and reliable conduct in full cooperation with the authorities in charge.

7 CONFLICT OF INTEREST

The recipients of the Code of Ethics shall avoid all situations and activities which involve even a potential conflict of interest between personal and family economic activities and their tasks within the related organization. Recipients are obliged to declare their situation of incompatibility or conflict of interest, before the start of management activities deemed sensitive. In particular, managers and employees for whom the Code of Ethics is intended shall declare to the office of the CEO if there are situations of conflict or potentially detrimental to the operations of the company, nor make unauthorized personal use of company assets.

8 CONTROL STRUCTURE OF THE CODE OF ETHICS

8.1 Validity of the Code of Ethics

Any violation of the provisions of this Code of Ethics will constitute a breach of the contractual obligations of the employment or functional or professional collaboration relationship, with all consequent legal and contractual effects. It shall also entitle the company to apply the disciplinary sanctions provided.

8.2 Verification of the actual application of the Code of Ethics

The application of the Code of Ethics is the responsibility of the CEO.

This Code of Ethics is fully disclosed to all recipients. The Chief Executive Officer shall perform the following tasks:

  • ensure compliance with the Code and related disclosure to all recipients;
  • verify any notice of violation of the Code and inform the competent company bodies and functions of the results of the verification for the adoption of any penalties;
  • propose amendments to the content of the Code in order to adapt to the changing context in which the company operates.

8.3 Reporting of violation of Company rules and unethical conduct

Cases of violation of law and/or company rules or this Code of Ethics shall be promptly reported in writing, in confidential form, to the office of the CEO.

8.4 Disciplinary penalties

The disciplinary sanctions provided for violations of the measures contained in this Code are intended to contribute to the effectiveness of the Code and the control of the office of the CEO. They shall be deterrent and commensurate to the seriousness of the violation, recidivism, absence or degree of guilt in respect of the provision in article 7 of the Law of 20 May 1970 no. 300 and the provisions contained in the employment contracts.

The application of the disciplinary system is independent from the development and outcome of any legal proceedings initiated by the relevant judicial Authorities.

As for suppliers, collaborators and external consultants, violation of the provisions of this Code is punishable with the termination of the existing contracts with the same, without prejudice to the right of the Company to claim compensation for damages incurred as a result of said conduct.

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In 2016 Toro Investigazioni has successfully managed 208 cases