Code of Ethics, Relationships of employees with third parties

3 – Relationships of employees with third parties

3.1 Relationships with collaborators not bound by an employment contract

Every Employee, in relation to his own functions and duties, shall be responsible for:

  • rigorously complying with internal procedures relating to the selection and management of relationships with Collaborators not bound by an employment contract;
  • carefully selecting suitably experienced/qualified individual with a sound reputation;
  • expressly referring in all collaboration contracts not involving an employer/employee relationship, to his/her obligation to adhere to the Principles of the Code of Ethics.
3.2 Relationships with clients and suppliers

In their relationships with Clients and Suppliers, Group Employees are obliged to:

  • conform to the provisions of the Code of Ethics;
  • comply rigorously with internal procedures relating to the management of relationships with Clients;
  • provide high-quality products and services that meet Clients’ reasonable expectations and safeguard their safety and security;
  • adopt the necessary standards of correctness in all communications of an advertising, commercial or other nature.

In bid contracts and in contracts for the purchase or procurement and, in general, supply of goods and services, Group Employees are required to comply with the principles of this Code of Ethics, as well as with internal procedures, adopting the written form. Whatever the case, Suppliers must be selected in accordance with the prerequisites of quality, pricing, economic advantage, ability and efficiency.
In particular, Group Employees must:

  • comply rigorously with prevailing legislation and with internal procedures relating to the selection and management of relationships with Suppliers;
  • in selecting supplier companies meeting the established prerequisites, adopt objective and transparent evaluation criteria;
  • obtain the co-operation of Suppliers in ensuring that the requirements of Customers are duly met in terms of quality, cost and delivery timescales;
  • in supply arrangements, comply with, and conform to, applicable legal requirements and contractually established conditions;
  • comply with principles of correctness and good faith in correspondence and in discussions with Suppliers, in keeping with the most rigorous business practice.

Employees may not:

  • receive any form of payment from anyone for performing any act that is part of their duties or conflicts with their duties of office;
  • give or receive, in any form, be it direct or indirect, gifts, presents or hospitality, except where the value of the same is such not to compromise the company’s image;
  • be conditioned in any way by third parties that are extraneous to the company in which they work and to the Group and are not authorised by them to do so, with regard to the making of decisions and/or the undertaking of activities relating to their work.

Any Employee receiving gifts or any other kind of benefit whose value is not modest, is required to notify the Guarantor to this effect.

3.3 Relationships with the public administration and/or relations of a publicistic nature

The Group’s relationships with the Public Administration, or in any event relations of a publicistic nature, must be founded upon the most rigorous pursuance of applicable legal and regulatory requirements and may not in any way compromise the Group’s integrity and reputation.

Only those company functions established for this purpose and authorised to do so may assume undertakings and manage relationships, of any kind whatsoever, with the Public Administration and/or those of a publicistic nature.

Whatever the case, during negotiations regarding business or during a relationship, including those of a commercial nature, with the Public Administration, in Italy or abroad, the Group agrees not to:

  • offer work and/or business opportunities to Public Administration staff involved in negotiations or the relationship concerned, or to their relatives, directly or indirectly;
  • offer gifts, except where of modest value and offered as a courtesy or in keeping with current practice.

In relations with the Public Administration, in Italy and abroad, representatives and/or Group Employees are not allowed to pay or offer, directly or through third parties sums of money or gifts of any kind or size, to any Public Officials, Government Representatives, civil Servants or private Citizens (be they Italian or foreign) with whom the Group has entered into business relations, in order to compensate them or repay them for an act they have performed as part of their duties of office or to get them to carry out an action that is contrary to their duties of office.

Items of modest value that are offered as a courtesy, such as gifts or forms of hospitality, or any other form of benefit (including those offered out of generosity) are only permitted where they are such not to compromise the integrity and reputation of the parties and cannot be interpreted as items given as a way of improperly obtaining advantages and favours.
In countries where it is customary to offer gifts to Clients or to others, the Group may only offer them where the gifts concerned are of an appropriate nature and of modest value, but may only act thus, under all circumstances, in accordance with the applicable laws, business practice and codes of ethics – where known – of the companies or entities with which the Group has relations.

3.4 Relationships with the authorities and other regulatory bodies

The Group undertakes to conform fully and rigorously to the rules laid down by the Supervisory Authorities and regulatory bodies.
Group Employees shall duly fulfil every request received from the Authorities and other regulatory bodies in their inspective roles, co-operating with the relevant procedures established for inquiry purposes.

3.5 Relationships with political organisations and unions

The Group does not make donations of any kind, be it directly or indirectly, to political parties, movements, committees and political organisations and unions, nor to their representatives or candidates, in Italy or Abroad.

3.6 Media relations

The responsibility for relationships between the Group and the mass media in general lies exclusively with those functions and managers charged with them. Such relationships are to be managed in accordance with the communications policy defined by the Group.

Group Employees may not therefore provide information to representatives of the mass media without authorisation from the competent functions.

Whatever the case, information and communications relating to the Group and sent outside of the organisation must be accurate, truthful, complete, transparent and consistent with each other.

The participation of any Employees, in the name of the Group or as its representative, in committees and associations of every kind, be they scientific, cultural or sectorial, must be properly authorised by the Group, in accordance with internal procedures.

Any Employees invited, in the name of the Group or as its representative, to partake in conferences, congresses or workshops, or to produce articles, essays or publications in general, are required to obtain the necessary authorisation to do so beforehand from their direct line Manager with regard to the wording, reports and any other document provided for this purpose.

3.7 No-profit initiatives

The Group may promote no-profit activities in order to endorse its commitment to activities that satisfy the widespread interests (worthy of appreciation, from an ethical, legal and social standpoint) of the community in which it operates. In accordance with the Principles of the Group, donations may therefore be made to no-profit associations that operate with proper bylaws and are of considerable cultural value or benefit on a nationwide scale.

Sponsorships, which may concern social, sport, entertainment, art and culture issues, are only to be provided to those events where quality is guaranteed.

  1. General Principles
  2. Ethical Principles
  3. Relationships of employees with third parties
  4. Corporate Governance. Transparency of accounting practice and internal audit procedures.  Anti money laundering
  5. Staff and workplace policies
  6. Safeguarding safety and protecting the environment
  7. Confidential information and privacy protection. Insider trading

Download Sofinter Group Code of Ethics in pdf format