Code of Ethics
Principles and Values
This document, named “Code of Ethics”, defines the principles, values and responsibilities that Eurgomma adopts towards the economic and social context in which it operates, in compliance with Italian Legislative Decree 231/2001 and the provisions of the Lombardy Region.
The Code represents a set of fundamental principles for the proper management of the Company and guides all activities, behaviours and internal and external relationships.
Recipients
The principles of the Code of Ethics are binding for Directors, Shareholders, employees, consultants and all those who operate, in any capacity, in the name and on behalf of Eurgomma.
Dissemination
Eurgomma ensures the dissemination of the Code, the training of recipients, the interpretation of its provisions, the verification of compliance and its constant updating.
Art. 1 – Principle of legality
Eurgomma operates in full compliance with applicable laws and regulations, with particular reference to Italian Legislative Decree 231/2001, promoting a corporate culture based on legality.
Art. 2 – Honesty and transparency
The Company acts with fairness, loyalty and transparency, avoiding unlawful conduct and strengthening its reputation in the market.
Art. 3 – Use of company assets
The improper use of company information, data and equipment for personal or unlawful purposes is prohibited.
Art. 4 – Confidentiality
All recipients are required to ensure the confidentiality of company information.
Art. 5 – Conflict of interest
Situations involving a conflict between personal interests and the interests of the Company must be avoided.
Art. 6 – Fair competition
Eurgomma promotes fair and transparent competition in the market.
Art. 7 – Protection of people
The Company values human resources, guarantees equal opportunities and prohibits all forms of discrimination.
Art. 8 – Safety and environment
Eurgomma ensures safe working environments and compliance with environmental regulations and workplace safety requirements, including Italian Legislative Decree 81/08.
Art. 9 – IT resources
The use of IT systems must be correct, monitored and compliant with applicable regulations.
Art. 10 – Relations with customers and suppliers
Any form of corruption, promise or acceptance of undue advantages is prohibited.
Art. 11 – Public Administration
Relations with public bodies must be based on fairness, transparency and legality.
Art. 12 – Accounting principles
Accounting records must be truthful, complete and transparent.
Art. 13 – Reporting of unlawful conduct — Whistleblowing
Eurgomma guarantees the confidentiality of whistleblowers and protection against retaliatory conduct.
Art. 14 – Sanctions
Violation of the Code may result in disciplinary and legal consequences.
Art. 15 – Approval
The Code of Ethics was approved on 2 January 2018 and is subject to periodic review.