4 – Relationships with third parties

4.1 Relationships with clients

At the base of the corporate values and essential to the continuity of the business is customer satisfaction by offering advanced products and services.

Sofinter Group promotes customer relationships based on honesty, transparency, integrity, and therefore it is the obligation of the Group Employees:

• to provide high quality products and services that meet the reasonable expectations of the customer and protect their safety and security;
• to comply with obligations and commitments towards them;
• to provide accurate, complete and true information;
• to be consistent with the advertising, commercial communications or any other kind.

 4.2 Relationships with suppliers

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. Each type of business relationship should be governed adopting the written form. In the event that the supplier fails to comply with these principles, Sofinter Group may reserve the right to take appropriate action coming, in most severe cases, to avoid of further collaboration. 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, verifying that they are meeting the suitable requirements of reliability and integrity;
• in selecting supplier companies meeting the established prerequisites, adopt objective and transparent evaluation criteria, not precluding to any who is in possession of the requirements to participate in the drawing up of tenders;
• 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.

4.3 Relationships with Public Administration and of a publicist nature

The Group’s relationships with the Public Administration, or in any event relations of a publicist 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. It is also required that the relationships with the Public Administration are monitored and documented in the demonstration of an act transparently, fairly and professionally by the Group.

The assumption of commitments and the management of relationships, of any kind, with the Public Administration and/or those of a public character are reserved exclusively to the authorized Company departments.

4.4 Relationships With 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 fulfill every request received from the Authorities and other regulatory bodies in their inspective roles, co-operating with the relevant procedures established for inquiry purposes.

4.5 Other relationships with third parties

The Group does not make donations of any kind, directly or indirectly, to political parties, movements, committees and political organizations, unions, or their representatives or candidates, both in Italy and abroad.

The participation of Employees in the name of or on behalf of the Group, to committees and associations of all kinds, be they scientific, cultural or industrial, must be approved by the Group in accordance with internal procedures.

Employees who are invited on behalf of the Group or as its representative to attend meetings, conferences or seminars, or to write articles, essays or publications in general, are required to obtain the prior approval of the Guarantor of the texts and any other documents prepared for this purpose.

4.6 relationships with Media

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 authorization from the competent functions.

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

4.7 Presents and gifts

The Employee shall not:

• receive any form of payment from anyone for the performance of an act of his office or contrary to official duties;
• give or receive, in any form, whether direct or indirect, presents, gifts, hospitality, unless the value of the same is of little value and does not affect the company’s image;
• subject to any form of conditioning by Group’s internal and external person, not been authorized, for decision-making and/or execution of actions relating to their work.

Employee who receives gifts, or other form of benefit not of small value, is required to notify the Guarantor.

In any case, during a business negotiation or a relationship, including commercial, with the Public Administration, in Italy or in other countries, the Group undertakes not to:

• directly or indirectly offer employment and / or commercial opportunities in favor of the Staff of the Public Administration involved in the negotiations or in the relationship, or their families;
• offer gifts, unless there is question of acts of kindness and of little value in current use.

In relations with the Public Administration, in Italy and abroad, is not allowed to representatives and/or Employees of the Group to pay or offer, directly or through third parties, payments or gifts of any kind and entity, whether Public Officers, public Employees and private Citizens, both Italian and from other countries, with which the Group has commercial relationships, to compensate or repay an act of their office or to achieve the performance of an act contrary to the duties of their office.

Courtesies of little value, such as gifts or hospitality, or any other form of benefit (including the form of donations) are permitted only if they do not compromise the integrity and reputation of the parties and can not be interpreted as acts aimed to obtain advantages and favors improperly.

In countries where it is customary to offer gifts to clients or to others, the Group may do so only in the event that these gifts are of an appropriate nature and of modest value, but always in compliance with applicable laws, the commercial practice and codes of ethics – If known – of the companies or entities with which the Group does business.

4.8 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.