Reputation is of fundamental importance to the Group. To this aim, it is necessary that during the running of business operations, the most appropriate principles of corporate governance are observed in order to ensure that the Group’s activities are undertaken as efficiently as possible, in keeping with rules of sound corporate governance and the provisions of this Code of Ethics, in the interest of Shareholders, Employees, Collaborators and all those persons entering into business relations and/or coming into contact with the Group.

The Group is committed to meeting the highest possible standards when adapting to the provisions and principles of self-regulation laid down by the Authorities responsible for the regulated markets in which the securities of Group companies might be listed.

Accounting entries

Every operation or transaction is to be correctly recorded in the company accounting system, in accordance with the criteria indicated by law and all applicable accounting standards. It must also be authorized, verifiable, lawful, consistent and proper.

To this aim, Group companies adopt accounting standards that meet requirements for truthfulness, completeness and transparency with regard to the data recorded; for every transaction effected, the inherent decision-making, authorization and execution process must be able to be verified, while adequate and complete documentation in support of the activity undertaken must also be stored as part of the Group’s official documents.

Each Employee is therefore required to co-operate – to the extent of his/her duties and responsibilities – so that any fact or event relating to the Group’s management is reported correctly and promptly to the competent functions and duly recorded in the relevant ledger.

Internal audit procedures

The term “internal audit procedures” means all instruments deemed necessary or useful for the purpose of steering, managing, verifying and realizing the activities of Group companies, the underlying aim being to ensure that laws and business procedures are duly adhered to, in order to protect company assets, effectively manage business activities and provide truthful and correct information regarding the Group’s property, performance and financial situation with transparency.

In this field is also included the checking the adequacy of business processes in terms of economy, efficiency and effectiveness and the reliability and accuracy of accounting records.

Mission of the Group is to spread, at all levels, an internal culture characterized by an awareness of the existence of checks and geared to the pursuit of the control.

As part of their functions and responsibilities, the Group’s Managers shall be required to partake in the realization and implementation of an effective business control system and to get all staff operating below them to become part of same system.

Group Employees shall therefore be required – to the extent of their duties and responsibilities – to:

• define and ensure the correct functioning of the aforementioned control system;
• responsibly look after all company assets (fixed and intangible alike) that are instrumental to the activities undertaken and ensure that they are not used improperly.

The Internal Audit Department and the Independent Auditing Firm appointed may freely access any data, documentation and information held useful in the undertaking of internal audit and accounting activities.

Anti Money Laundering

The Group does not permit any kind of money laundering. Employees and Collaborators must verify in advance the moral integrity of the people with whom they have working dealings through a control of the information available. The Group is committed to conforming to all legal requirements relating to “anti-money laundering” in those countries in which the Group operates.