FAIRMAT S.R.L. is a provider of IT solutions (software and other innovative products/services) with the goal of simplifying and automating the management of assessment and financial analysis and regulatory processes, mainly for Banks, Insurance Companies and Investment Funds.
FAIRMAT S.R.L. adopts this “Code of Ethics and Conduct” in the belief that the rules provided are a valid guidance for all recipients (directors, employees, collaborators) and a spur to an increase in value even from an ethical and non-equity point of view of the company.
Application of the Code and Recipients
The “Code of Ethics and Conduct” encompasses a set of guidelines and behavior rules that are deemed to be of primary importance for achieving corporate goals.
The principles and provisions of the Code are binding on the Directors, all the people related by subordinate employment relationships with FAIRMAT S.R.L. (“Employees”) and all those who act for the Company, irrespective of the relationship, even temporary relationship, that binds them to the Company (“Collaborators”). Directors, Employees and Collaborators are hereinafter jointly referred to as “Recipients”.
The set of these rules lays down the diligence, correctness and fairness obligations, meaning a guideline criterion for all the Group companies.
The Company is committed to ensuring that all the Recipients may have access to the contents of this Code, providing a suitable training program and also undertaking not to start and carry on any relationship with those who do not intend to align themselves with the principles of this Code. The Recipients are required to be aware of the content of this Code and to abide by.
While carrying out its own activity the Company, with reference to its specific function, must comply with the following principles:
Relationships and Hierarchy
We deem to be of crucial importance as part of the corporate activities compliance with the hierarchical criteria as set down by the Board of Directors’ resolutions and, for the employees, by the positions held.
The employees perform their working activity and provide their services in compliance with any rule with diligence, professionalism, efficiency and correctness, making the best use of the tools and time available and assuming liability for their acts and/or omissions.
Protection of goods and information owned by the Company
All Recipients shall endeavor diligently to protect the corporate goods entrusted to them for performing their tasks, keeping them scrupulously and avoiding improper or prejudicial uses thereof.
When performing their functions, all Recipients are required to properly use in compliance with the existing regulations, telephone systems, access to electronic mail, Internet and Intranet and refrain from using them for purposes other than professional ones and taking into account that all information of the IT system belongs to the Company.
Legitimacy, Authorization and Traceability of Processes
Each operation and transaction shall be correctly recorded, authorized, verifiable, legitimate, consistent and appropriate. There must be supporting documentation for each operation suitable for permitting at any time to make checks that certify the characteristics and reasons of the operation and identify who has authorized, made, recorded and verified the operation.
Conflicts of Interest
The Recipients shall pursue in their activities only and exclusively the interests of the Group Companies, avoiding any situations that reveal conflicts of interest.
“Conflicts of interest” means the situations where an interest other than that of the company is pursued, or activities are carried out that may prevent to take decisions in the exclusive interest of the company or even through which you, personally, take advantage of business opportunities of the company, or in which the representatives of customers, suppliers, public institutions or public officials or persons in charge of public service act in conflict with the fiduciary duties connected with their position.
By way of example, but not limited to, a conflict of interest consists of:
The Recipients ensure utmost confidentiality of the news and information that are the corporate assets or relating to the activity of the company, in compliance with the provisions of law, regulations in force and the in-house procedures.
All transactions and operations made shall be suitably recorded and it must be possible to check the decision-making, authorization and carrying out process. Each operation shall have a suitable documentary support in order to be able to make, at any time, checks that certify the characteristics and reasons of the operation and identify who has authorized, made, recorded and verified the operation.
La Società tutela la sicurezza e la salute nei luoghi di lavoro, che ritiene fondamentale, nell’espletamento
dell’attività economica. Tale politica è esplicitata nel documento “Politica aziendale per la salute e sicurezza dei lavoratori” (e successive integrazioni e modificazioni) disponibile per la visione presso la Società stessa.
La Società si impegna, mettendo a disposizione risorse umane, strumentali, ed economiche, a perseguire gli obiettivi di miglioramento della sicurezza e salute dei lavoratori come parte integrante della propria attività e come impegno strategico rispetto alle finalità più generali dell’azienda.
La gestione dei rapporti di lavoro è orientata a favorire la crescita professionale dei dipendenti.
L’assunzione del personale dovrà avvenire in conformità alla normativa vigente e solo per accertate capacità professionali.
Nei rapporti coi dipendenti e nell’esercizio di ogni attività, la Società si astiene da ogni discriminazione basata sull’età, il sesso, la sessualità, lo stato di salute, l’etnia, la nazionalità, le opinioni politiche e religiose nei confronti di tutti i suoi interlocutori. La Società rispetta i diritti della persona e ne sostiene l’osservanza e agisce in conformità ai principi sanciti dall’Organizzazione internazionale del lavoro.
The Company acknowledges the primary value of human resources being convinced that the main success factor for any company is the professional contribution of the people who work there in a framework of loyalty and mutual trust.
The Company safeguards the safety and health at the workplaces, which it deems to be essential while carrying out the economic activity. This policy is explained in the “Corporate policy for health and safety of the workers” document (as amended) available for viewing at the Company. While making human, instrumental and economic resources available, the Company undertakes to pursue the objectives of improving workers’ safety and health as part of its own activity and as strategic commitment for the more general purposes of the company.
The management of working relationships is addressed to promoting professional growth of employees.
Staff hiring shall take place in compliance with existing regulations and for ascertained professional skills only.
In the relationships with employees and while performing any activity, the Company refrains from any discrimination based on age, sex, sexual orientation, health status, ethnic group, nationality, political and religious opinions towards all its interlocutors. The Company respects the rights of the person and supports their observance and acts in compliance with the principles laid down by the International Labor Organization.
Respect for the environment
The Company, when carrying out its specific activity, undertakes:
Respect For The Privacy And Data Protection
The Company warrants the processing of personal and sensitive information in its possession relating to collaborators, business partners, customers and suppliers in full compliance with the relevant regulations; for this purpose, it implements suitable measures to protect the inviolability of data and its correct processing. The Company ensures the utmost protection of information and data in its possession, undertaking to use them within the limits provided for by the regulations in force.
Relationships with Institutions
The Company maintains, with all public institutions, relationships of fair collaboration respecting the independence of everyone and in full compliance with the regulations in force.
The relationships with the Public Administration and public officials have to conform to the following principles:
The Recipient is required to not hold assignments in the Public Administrations or public or private Entities that may be incompatible with the Assignment held with the Company.
In the course of notices and reports, the Group companies warrant the completeness and integrity of news and objectivity of evaluations, ensuring the timeliness of the required obligations.
Relationships with Suppliers and Third Parties
The relationships with suppliers of goods and services shall be based on utmost correctness, taking into account exclusively the interest of the Company. The selection of suppliers and determination of the purchase terms are based on an objective assessment of the quality, price and capacity to supply and guarantee services of a suitable level over the time.
The employees may not receive gifts, presents or other benefits that do not fall within the normal courtesy relationships. The employee who receives presents or another kind of benefit, not directly attributable to normal courtesy relationships, shall take any appropriate initiative in order to refuse this present or another kind of benefit and shall inform its superior thereof.
The Company provides support to social, cultural and educational initiatives aiming at the promotion of the person and knowledge of history and culture.
The Company does not provide contributions, advantages or other benefits to the political parties and workers’ trade union organizations nor to their representatives or candidates.
The Company undertakes to inform all parties involved of the provisions of the Code for the purposes of their compliance.
In particular, the company, through the appointment of specific in-house functions, shall:
Each employee shall be informed of provisions provided for in this Code by delivering a copy, of which it shall issue a receipt in writing. The formal acceptance of provisions of this Code may be requested by the relevant Functions to the other Recipients of the Code.
Integration in the Model 231 and Review of the Code
This Code of Ethics is an integral part of the Organizational Model in accordance with Legislative Decree 231/01 adopted by the Company and, as such, is submitted to checks by the Supervisory Body. Any non-compliance found, both by the senior management and staff working under the instructions of superiors, and by any other Recipient shall entail application of the disciplinary measures provided for by the Model, including termination for just cause of the existing relationships.
The Code of Ethics and Conduct shall be submitted to verification from time to time, both with reference to the legislative innovation and as a result of amendments of operativeness of the company and/or its in-house organization.
Proposals of amendment shall be submitted to the attention of the Board of Directors for the required approval.