Code of Ethics

INTRODUCTION

The Association Centro Studi Aziendali Mediterraneo has adopted this Code of Ethics, an integral part of its Organisation, Management and Control Model pursuant to Legislative Decree 231/01, as amended by Decree-Law 92/2008 and Decree-Law 93/2013

1.1 Purpose of the Code of Ethics

The Code of Ethics sets out the relevant ethical principles and rules of conduct for the prevention of offences and contains, specifically, the set of rights, duties and responsibilities towards “stakeholders”: employees, collaborators, suppliers, clients, public and private users and, more generally, towards the social and economic context in which the Association operates.

1.2 Recipients of the Code of Ethics

The rules of this Code of Ethics are binding and apply to all employees of the Association Centro Studi Aziendali Mediterraneo, as well as to external collaborators and consultants acting in the name and/or on behalf of the organisation. Under no circumstances may the claim of acting in pursuit of an interest or advantage for the Association Centro Studi Aziendali Mediterraneo justify conduct that conflicts with that set out in this document.

1.3 Contractual value of the Code of Ethics

Compliance with the rules of the Code of Ethics must be considered an essential part of the contractual obligations of the employees of the Association Centro Studi Aziendali Mediterraneo pursuant to art. 2104 et seq. of the Italian Civil Code. Any breach of the rules of this Code of Ethics damages the relationship of trust established with the Association Centro Studi Aziendali Mediterraneo and will be sanctioned in proportion to the seriousness of the infringement committed, without prejudice, for employees, to compliance with the procedures of the applicable Regional Collective Labour Agreement (CCRL) and of the Workers’ Statute (Law 300/1970).

Breaches committed by third parties will be sanctioned according to the criteria set out in the specific clauses (express termination clauses and/or penalty clauses) included in contracts with third parties, so that they act in compliance with this Code of Ethics.

1.4 Commitment to the application, dissemination and updating of the Code of Ethics

The Code of Ethics is brought to the attention of all identified recipients. In particular, the Association Centro Studi Aziendali Mediterraneo ensures, through the competent internal functions, the widest dissemination of the Code of Ethics among its employees, in order to facilitate understanding of its guiding principles. The Association Centro Studi Aziendali Mediterraneo ensures that all recipients and stakeholders are fully aware of the Code of Ethics and of all its subsequent updates, allowing them to obtain any further information and clarification.

The Association Centro Studi Aziendali Mediterraneo makes the Code fully accessible, using every useful means to ensure the widest visibility and publicity, for example through e-mail communications, publication on the website, posting on the notice board, and reference to the Code in the clauses of employment contracts and of contracts with consultants. The Association Centro Studi Aziendali Mediterraneo is also committed to adapting the contents of the Code of Ethics to changes in legislation, carrying out the appropriate checks whenever it receives reports of breaches of the adopted rules, and applying the sanctions provided for when such breaches are established.

1.5 Obligations of the directors, employees and collaborators of the Association Centro Studi Aziendali Mediterraneo

The directors, employees and collaborators of the Association Centro Studi Aziendali Mediterraneo are required to know the principles and contents of this Code of Ethics and the relevant rules governing the activities of their role deriving from the Law or from internal procedures and regulations. Specifically, they are required to:

  • refrain from conduct contrary to such rules, principles and regulations;
  • contact their supervisors and the Board of Directors to request clarification on their application;
  • promptly report to the Board of Directors any possible cases of, or requests to commit, breaches of the Code of Ethics;
  • cooperate, if requested, in the verification of any breaches;
  • adequately inform any third party about the existence of the Code of Ethics and the commitments and obligations it imposes on external parties.

1.6 Reference ethical principles

TRAINING AND PROFESSIONAL GROWTH

The Association Centro Studi Aziendali Mediterraneo welcomes every individual, whatever their employment status, contributing to their professional and personal growth and training, and promoting and supporting everyone’s right to education and training, with respect for their identity and culture. The aim of the Association Centro Studi Aziendali Mediterraneo is to welcome each individual as a whole, promoting, through inclusive training processes, their overall personal and professional growth so that the individual acquires social value through their own professionalism.

QUALITY OF TRAINING

To offer users competence-based vocational training aligned with high-quality professional profile standards, and to promote and apply quality assurance principles in education and training, in tune with the needs of the area and with the need to integrate with the whole economic, political and social system.

FREEDOM OF TEACHING

Educational and teaching planning ensures respect for freedom of teaching and promotes the education of users through formal, non-formal and informal learning.

COMPLIANCE WITH PROGRAMMES

Teaching is carried out in accordance with regional programmes and in line with the relevant legislation; it aims at the harmonious and balanced personal, relational and cognitive development of students.

The elements considered essential to achieve this result are:

  1. Consistency of teaching choices with the Training Project;
  2. Shared teaching choices among all those involved;
  3. A constructive climate between teachers and students based on listening and dialogue;
  4. Attention to people on the part of all staff;
  5. Awareness of the need to seek close alignment between:
  • Managers of the Association Centro Studi Aziendali Mediterraneo, who are responsible for understanding and interpreting the signs and trends of the times and the changing needs and expectations of businesses, workers, families and students.
  • Stakeholders representing the social, economic and working fabric of the local area.
  • Teachers and Consultants, the operational heart of the Association Centro Studi Aziendali Mediterraneo, who interpret and translate the objectives to be pursued and are effective, competent and exemplary instruments.
  • Students, beneficiaries and workers, key figures for the Association Centro Studi Aziendali Mediterraneo, who are offered a training pathway aimed at acquiring skills and autonomy, the necessary conditions for exercising their profession.

DEVELOPMENT OF HUMAN CAPITAL

The Association Centro Studi Aziendali Mediterraneo places the person at the centre of every initiative and activity, valuing diversity and identifying the tools to develop each person’s potential; the management of human resources at the Association Centro Studi Aziendali Mediterraneo is based on respect for the personality and professionalism of each person, in a framework of loyalty and trust.

FAIRNESS, AUTONOMY AND MORAL INTEGRITY

In its relations with stakeholders, the Association Centro Studi Aziendali Mediterraneo undertakes to act fairly and transparently, avoiding misleading information and any conduct that takes advantage of situations of weakness or lack of knowledge; the Association Centro Studi Aziendali Mediterraneo acts with diligence and good faith, honouring the commitments it has made.

TRANSPARENCY

The Association Centro Studi Aziendali Mediterraneo pursues transparency within the organisation, among collaborators and towards the recipients of its services; the employees and collaborators of the Association Centro Studi Aziendali Mediterraneo are required to provide users/clients with complete, transparent, understandable and accurate information, so that they are aware of the characteristics and purposes of the services.

CONFIDENTIALITY

The Association Centro Studi Aziendali Mediterraneo ensures the confidentiality of the information in its possession and refrains from seeking confidential data, except with express and informed authorisation and in compliance with the legal rules in force; in addition, the collaborators of the Association Centro Studi Aziendali Mediterraneo are required not to use confidential information for purposes unrelated to the performance of their activities.

ATTENTION TO USERS

The Association Centro Studi Aziendali Mediterraneo directs its activities towards the satisfaction of its clients, listening to requests that may help improve the quality of its services; the conduct of the Association Centro Studi Aziendali Mediterraneo towards users is based on helpfulness, respect and courtesy, with a view to a cooperative and highly professional relationship.

FAIRNESS IN THE EVENT OF POTENTIAL CONFLICTS OF INTEREST

In carrying out any activity, situations of conflict of interest, even potential ones, must always be avoided, i.e. situations in which an Employee, Consultant, External Collaborator or Partner pursues an interest other than that of the Institute or takes personal advantage of business opportunities in the performance of their duties.

LEGALITY

The Association Centro Studi Aziendali Mediterraneo undertakes to comply with all national and international rules, laws, directives and regulations and with all generally recognised practices, and bases its decisions and conduct on care for the public interest entrusted to it.

RESPONSIBILITY TOWARDS THE COMMUNITY

The Association Centro Studi Aziendali Mediterraneo wishes to play an active role in the community in the education, training and specialisation/retraining of students and workers.

ENVIRONMENT, HEALTH AND SAFETY

The Association Centro Studi Aziendali Mediterraneo is committed to respecting the environment and to preventing and protecting against health and safety risks for students and staff. In particular, when using laboratory materials, the Association Centro Studi Aziendali Mediterraneo uses only products that comply with the applicable regulations and disposes of them in accordance with the regulations in force.

The Association ensures the safety of students during laboratory activities and guarantees hygienic and safe environmental conditions.

INTEGRITY AND PROTECTION OF THE PERSON

The Association Centro Studi Aziendali Mediterraneo undertakes to protect the moral integrity of its Employees and External Collaborators, guaranteeing the right to working conditions that respect the dignity of the person. For this reason, it protects workers from acts of psychological violence and opposes any discriminatory attitude or behaviour, or any behaviour harmful to the person, their beliefs and preferences (for example insults, threats, isolation or excessive intrusiveness, professional restrictions and any gender discrimination). Sexual harassment is not permitted, and behaviour and language that may offend a person’s sensibilities must be avoided (for example the display of images with explicit sexual references, or insistent and repeated innuendo). Any Employee or External Collaborator of the Association Centro Studi Aziendali Mediterraneo who believes they have been harassed or discriminated against on grounds of age, sex, sexuality, race, health, nationality, political opinions, religious beliefs, etc. may report the matter to the Management, which will assess whether the Code of Ethics has actually been breached.

STATEMENT OF INTENT AND RULES OF CONDUCT TOWARDS THIRD PARTIES

In accordance with the ethical principles stated, the Association Centro Studi Aziendali Mediterraneo undertakes to:

  • combat unlawful conduct: consistent with the values of honesty and transparency, the Association Centro Studi Aziendali Mediterraneo undertakes to implement all the measures necessary to prevent and avoid the commission of offences. In particular, it prohibits the payment of sums of money or any other form of corruption aimed at obtaining direct or indirect advantages for the organisation itself. It also prohibits accepting gifts or favours from third parties that go beyond the normal rules of hospitality and courtesy;
  • avoid conflicts of interest: the Association Centro Studi Aziendali Mediterraneo does not allow its employees and collaborators to be involved in relationships that may lead to conflicts of interest with their organisational role. This applies both when an employee or collaborator pursues an interest other than the association’s mission or takes personal advantage of the association’s business opportunities, and when representatives of clients, suppliers or the Public Administration act in breach of the fiduciary duties connected with their position;
  • avoid corruption: it is not permitted to offer/receive, directly or indirectly, money, gifts or benefits of any kind on a personal basis to/from managers, officials or employees of clients, suppliers, Public Administration bodies, Public Institutions or other Organisations in order to obtain undue advantages or to influence the recipient’s independent judgement.

The rules of conduct for the different types of recipients are set out below:

Selection of teaching and non-teaching staff

Selection takes place in accordance with internal procedures, comparing the expected skills profile with the person’s characteristics and assessing their consistency with the association’s values.

All staff must be hired under a regular employment contract; no form of irregular or undeclared work is permitted. When the collaboration begins, the employee/collaborator must receive comprehensive information on the characteristics of their tasks and role, on regulatory and pay aspects, and on the rules and conduct for managing risks relating to health, safety and privacy.

They must also explicitly accept their commitments deriving from this code of ethics.

Relations with employees and collaborators

The Association Centro Studi Aziendali Mediterraneo requires its employees/collaborators to know and comply with the provisions of the Code of Ethics.

Employees and collaborators are required to report any breach of the Code of Ethics by colleagues, collaborators and consultants of which they become aware. The Association Centro Studi Aziendali Mediterraneo also provides for disciplinary measures for any unfounded report made in bad faith with the intention of deliberately harming colleagues and/or collaborators, or for any failure to report well-founded cases.

Collaborators and consultants who have relations with the Association Centro Studi Aziendali Mediterraneo are required to avoid any situation of conflict of interest with it and undertake, in the event of a conflict, to report it immediately to the organisation.

Relations with clients and suppliers

Professionalism, competence, transparency and fairness are the guiding principles that the recipients of the Code must follow in their relations with all suppliers of services, works, materials and professional services. Every acquisition of services, works, materials or professional services must be carried out with loyalty, confidentiality, diligence, professionalism and impartiality, by qualified staff who take responsibility for their own assessments and judgements, ensuring compliance with all the regulations in force in the performance of their activities. Employees involved in these procurement processes must guarantee the utmost independence in carrying out the tasks entrusted to them, remaining free from personal obligations towards suppliers. Any personal relationships between employees and suppliers must be reported to the Management before any negotiation.

It is also strictly forbidden:

  1. to offer goods or services, in particular in the form of money or other benefits, to directors, general managers, managers responsible for preparing corporate accounting documents, statutory auditors, liquidators or persons under the direction or supervision of any of the above, of third-party companies or organisations, in order to induce them to perform or omit acts in breach of the obligations of their office or of their duty of loyalty, with the aim of obtaining confidential information or any direct or indirect benefit for themselves and/or for the Association Centro Studi Aziendali Mediterraneo;
  2. to accept goods or services from external parties that would entail a breach of the obligations of one’s office. Information acquired in the course of relations with suppliers must be kept strictly confidential.

When starting business relations with new clients and/or suppliers and when managing existing ones, it is forbidden, on the basis of public information and/or information available in compliance with the regulations in force, to establish or maintain relations with parties:

  • involved in unlawful activities, in particular those connected with the offences referred to in Legislative Decree 231/2001, and in any case with parties lacking the necessary requirements of reliability and commercial trustworthiness;
  • who, even indirectly, behave in a way that does not respect human dignity and individual personality and/or violates fundamental human rights (exploiting child labour, facilitating migrant trafficking, etc.);
  • who do not comply with workers’ health and safety regulations and, in general, with all the rules contained in this Code of Ethics.

Relations with the Public Administration

Relations with the Public Administration must be based on the utmost transparency and fairness. In particular, the necessary relations must be maintained in compliance with the roles and functions assigned by law and in a spirit of full cooperation with state administrations, in Italy or in other countries.

It is clearly forbidden to falsify, alter or omit data and/or information in order to obtain an undue advantage or any other benefit for the Association Centro Studi Aziendali Mediterraneo.

Except for gifts of modest and symbolic value, it is not permitted to offer gifts to managers, officials and employees of the Public Administration or to their relatives, in Italy or abroad.

It is not permitted to offer or accept gifts or favours of value in order to obtain more favourable treatment in any relationship with the Public Administration.

In the course of relations (contacts, requests, negotiations, etc.) with the Public Administration, the internal and external staff of the Association Centro Studi Aziendali Mediterraneo in charge are not permitted to try to improperly influence the decisions of the other party.

The Association Centro Studi Aziendali Mediterraneo may not be represented in its relations with the Public Administration by third parties, consultants, etc. where conflicts of interest may arise. In any case, the Association Centro Studi Aziendali Mediterraneo must ensure that the third party and its collaborators apply the same ethical guidelines that apply to its own collaborators.

Relations with supervisory and control authorities

The Association Centro Studi Aziendali Mediterraneo bases its relations with all supervisory and control authorities (e.g. Labour Inspectorate, Audit Authority, Data Protection Authority, Provincial and Regional Public Administrations, etc.) on the fullest cooperation and full respect for their institutional role, undertaking to promptly comply with any instructions they may issue.

Use of Internet access

The Association Centro Studi Aziendali Mediterraneo undertakes to avoid the use of Internet access for reasons not strictly related to work and, in particular, prohibits its use to obtain or distribute pornographic material (especially if it concerns minors under 18).

Consequently, also in order to avoid damage to its image:

  • IT procedures are used which, by means of special “filters”, prevent Employees and/or Collaborators from accessing websites displaying pornographic material;
  • Employees and collaborators of the Association Centro Studi Aziendali Mediterraneo are in any case strongly advised:
  • not to access websites displaying pornographic material;
  • not to gain unauthorised access to computer and telecommunication systems protected by security measures (of the State, public bodies or any third party);
  • not to disclose access codes;
  • not to damage, alter or destroy information, data, programs and computer/telecommunication systems;
  • not to unlawfully intercept, prevent or interrupt computer or telecommunication communications;
  • not to produce false public electronic documents or documents with evidential value;
  • not to commit computer fraud.

Each of these types of behaviour constitutes conduct punishable under criminal law.

Prohibition of terrorist activities or activities subverting the democratic order

The Association Centro Studi Aziendali Mediterraneo is opposed to any form of activity carried out for the purposes of terrorism or subversion of the democratic order.

Therefore, also in order to avoid damage to its image:

  • Employees, Consultants, External Collaborators and Partners of the Association Centro Studi Aziendali Mediterraneo are forbidden from carrying out any form of activity for the purposes of terrorism or subversion of the democratic order;
  • any Employee or collaborator of the Association Centro Studi Aziendali Mediterraneo who has well-founded suspicions that a colleague is carrying out activities for the purposes of terrorism or subversion of the democratic order must immediately inform the public security authorities and the Management, which will take every initiative to actively cooperate with those authorities.

CODE OF CONDUCT FOR SENSITIVE PROCESSES AND ACTIVITIES

An analysis of each offence provided for by Legislative Decree 231/2001 in relation to the institutional activities of the Association Centro Studi Aziendali Mediterraneo has shown that the offences that could potentially be committed are:

  • offences against the public administration;
  • computer crimes and unlawful data processing;
  • corporate offences;
  • offences of serious negligent injury committed in breach of the rules on health and safety at work;
  • offences of receiving stolen goods, money laundering, self-laundering and use of money, goods or benefits of unlawful origin;
  • copyright infringement offences;

The offences listed above have highlighted the following risk areas:

  • management of relations with supervisory authorities (Data Protection Authority, INPS, ESF Managing and Audit Authorities, etc.);
  • management of tax obligations and relations with tax offices;
  • management of human resources obligations;
  • management of legal relations;
  • management of funding/subsidised contributions granted by the State, the Regions or the European Community;
  • preparation of the annual financial statements and of statements of assets and liabilities in the event of extraordinary transactions;
  • accounting management;
  • procurement
  • management of the workplace safety system;
  • IT system management;
  • delivery of training;

The offence risk areas identified above have been the reference point for defining a number of control procedures which, in order to avoid the offences identified as potentially possible, have introduced prohibitions, specific obligations and rules so that only conduct considered ethically correct is carried out.

This English translation is provided for information only; in case of discrepancy, the Italian version prevails.