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:

  1. Correctness and Honesty. The Company carries out its own activity with correctness and honesty. All subjects who carry out, either directly or indirectly, any activity for the Company or on its behalf are required to act in compliance with these principles. Fraudulent practices and behaviors, bribery acts, favoritisms and, more generally, conducts contrary to law, industry regulations, in-house regulations in force in all the countries where it does business, are prohibited. In particular, it is prohibited to perform any action that, with a view to bringing benefits to oneself or to the Company, could even only be interpreted as exceeding normal business or courtesy practices. The Recipient is liable to have the professional, scientific and moral prerequisites required by the Company to fulfil his assignment in compliance with the above-mentioned principles of Correctness and Honesty.
  2. Compliance with laws The Company has as its essential principle compliance with laws and regulations in force in all the countries where it does business. The Recipients shall perform their tasks in full compliance with the benchmark regulatory framework. The Recipients are prohibited any behavior that may constitute any kind of offence whatsoever, in particular, if provided for by Legislative Decree 231/01 as amended. The Recipient should not have convictions, even not final convictions, nor be aware of any investigations, for crimes related to his own profession and, more generally, for crimes that may concern the Activity of the Company and the relationships with Public Administrations.
  3. Compliance with corporate rules. The Company prepares and disseminates within its organization corporate rules in full compliance with workers’ rights, existing provisions and the benchmark collective bargaining agreement. All Recipients shall inform themselves and comply with these directions according to their duties and tasks.
  4. Sustainability. The Company undertakes to plan and implement, in each of its operation sectors, choices capable of ensuring the achievement of the pursued objectives without prejudice to the objectives of balanced well-being of the community and the environment preservation in the long run. When choosing this approach the Company intends to take into account, besides the environmental dimension, the economic and social dimensions, aware that progress and well-being are genuine only when their maintenance may be safeguarded even for the next generations.


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 evident or hidden interest in activities of suppliers, customers, competitors;
  • taking advantage of one’s position for achieving interests conflicting with those of the company;
  • the use of information acquired while carrying out working activities for your own benefit or that of third parties and, in any case, conflicting with the interests of the company;
  • carrying out of any kind of working activities (work performance, intellectual performance) with customers, suppliers, competitors and/or third parties conflicting with the interests of the company.



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.


Accounting Records

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.


Human Resources

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:

  1. to take the measures to restrain and – if possible – to cancel the negative impact of the economic activity on the environment not only when the risk of harmful or dangerous events is proven (principle of preventive action), but even when it is not certain whether and to what extent the activity of the company would expose the environment to risks (precautionary principle);
  2. to encourage the adoption of measures to prevent any harm to the environment rather than to wait for repairing a damage already occurred;
  3. to plan an accurate and constant monitoring of the scientific progress and regulatory evolution on environmental matters;
  4. to foster the training value and that of sharing the principles of the code among all the senior management and subordinates who work in the company, so that they would abide by the ethical principles laid down, especially, when decisions have to be taken and later on when they have to be implemented.


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:

  1. It is not allowed to offer money or gifts to managers, officials or employees of the Public Administration or to their relatives, either Italian or of other countries, unless these are gifts or useful items of modest value.
  2. It is prohibited to offer or accept any object, service, performance or favor of value to obtain a more favorable treatment in relation to any relationship with the Public Administration.
  3. When any business negotiation, request or relationship with the Public Administration is underway, the staff in charge must not try to improperly affect the decisions of the other party, including those of the officials that deal with or make decisions on behalf of the Public Administration.
  4. When the Company avails itself of a consultant or “third” subject to be represented in the relationships with the Public Administration, the same directions valid also for the employees of the company shall apply to the consultant and his staff or the “third” subject.
  5. The Company shall not be represented, in the relationships with the Public Administration, by a consultant or a “third” subject when conflicts of interest may arise.
  6. During a business negotiation, request or commercial relationship with the Public Administration, the following actions must not be undertaken (either directly or indirectly):
    • to examine or to propose employment and/or commercial opportunities that may personally benefit employees of the Public Administration;
    • to offer or, in any way, to provide gifts;
    • to solicit or to get confidential information that may jeopardize the integrity or reputation of both parties.
  7. Any (actual or potential) breach committed by the company or third parties shall be promptly reported to the relevant in-house functions.

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:

  • disseminate the Code to the Recipients;
  • construe and clarify the provisions;
  • check the actual compliance;
  • take measures connected with removal of infringements of the rules laid down in the Code;
  • update the provisions with regard to the requirements that arise from time to time.

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.