Ethical Code of Pragma Etimos
This Code of Ethics has been approved by the Board of Directors of Pragma Etimos S.r.l.
The Vision of Pragma Etimos SRL
PE – PRAGMA ETIMOS SRL is aware that the authority of a company is recognized not only by the competence of its collaborators and the high quality of the service provided to customers, but also by the attention paid to the needs of the entire community.
The principles that have always inspired the work of this Company are formally collected in a Code of Ethics of Conduct in the belief that reliability is built on a daily basis by respecting the rules and valuing people.
This Code of Ethics represents, therefore, a distinctive and identifying element towards the market and third parties, whose knowledge and sharing, required of all those who work in the Company or who collaborate with it, constitute the foundation of our activity and the first step to contribute to the pursuit of our vision.
The objective of PRAGMA ETIMOS SRL is therefore to pursue excellence in the market in which it operates, through Sustainable Development, safeguarding the Environment and the Safety of the people involved through the consistency of a behavior that respects Social Ethics, obtaining satisfaction and ensuring added value for the Employee, for the Customer and, in general, for the Community.
Purposes and recipients
This Code of Ethics (hereinafter, the “Code“) illustrates the set of ethical and moral principles that underlie the activities of PRAGMA ETIMOS SRL (hereinafter, the “Company”) as well as the lines of conduct adopted by the Company both within its own business (in relations between employees) and externally (in relations with institutions, suppliers, customers, business partners , political and trade union organisations as well as media outlets (hereinafter, the “Stakeholders“).
Compliance with these principles is of fundamental importance to achieve the corporate mission of PRAGMA ETIMOS SRL and to guarantee its reputation in the socio-economic context in which it operates.
First of all, it should be noted that PRAGMA ETIMOS SRL firmly believes that every activity must be carried out ethically, recognizing itself in the principle enshrined in Article 41 of the Constitution, according to which private economic initiative “may not be carried out in contrast with social utility or in such a way as to cause damage to security, freedom, human dignity.”
This Code is binding for the directors and employees of PRAGMA ETIMOS SRL, as well as for all those who work and collaborate, permanently or on a fixed-term basis, on behalf of the Company (hereinafter, the “Recipients”).
The Code will be widely disseminated within the internal governance structure, and widely communicated externally, including through its website.
PRAGMA ETIMOS SRL also undertakes to adopt any further provisions so that the principles and provisions of the Code can be promptly disclosed and applied.
General Principles
The conduct of the Recipients, at all levels of the company, is based on the principles of legality, fairness, non-discrimination, confidentiality, diligence, and loyalty.
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Legality
PRAGMA ETIMOS SRL operates in absolute compliance with the law and this Code.
All Recipients are therefore required to comply with all applicable regulations and to constantly update themselves on legislative developments, also by making use of the training opportunities offered by PRAGMA ETIMOS SRL.
The Company considers the transparency of financial statements and accounting to be a fundamental principle for the exercise of its business and for the protection of its reputation.
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Fairness
Fairness and moral integrity are an indefectible duty for all Recipients.
The Recipients are required not to establish any privileged relationship with third parties, which is the result of external solicitations aimed at obtaining improper advantages.
In carrying out their activities, the Recipients are required not to accept donations, favours or benefits of any kind (except for objects of modest value) and, in general, not to accept any quid pro quo in order to grant advantages to third parties in an improper way.
In turn, the Recipients must not make donations of money or goods to third parties or in any case offer illicit benefits or favors of any kind (except for objects of modest value or gifts of commercial courtesy authorized by the Company) in connection with the activity they provide for the benefit of PRAGMA ETIMOS SRL.
The intrinsic conviction of acting in the interest of the Company does not exempt the Recipients from the obligation to comply with the rules and principles of this Code.
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Non-Discrimination
In relations with Stakeholders and in particular in the selection and management of personnel, in the organization of work, in the choice, selection and management of suppliers, as well as in relations with Bodies and Institutions, PRAGMA ETIMOS SRL avoids and repudiates any discrimination regarding age, sex, race, sexual orientation, state of health, political and trade union opinions, the religion, culture and nationality of the interlocutors.
PE – PRAGMA ETIMOS SRL, at the same time, promotes integration, promoting intercultural dialogue, the protection of the rights of minorities and vulnerable individuals.
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Confidentiality
PRAGMA ETIMOS SRL undertakes to ensure the protection and confidentiality of the personal data of Recipients and Stakeholders, in compliance with all applicable legislation on the protection of personal data.
The Recipients are required not to use confidential information, learned as a result of their work activity, for purposes unrelated to the exercise of such activity, and in any case to always act in compliance with the confidentiality obligations assumed by PE – PRAGMA ETIMOS SRL towards all Stakeholders.
In particular, the Recipients are required to maintain the strictest confidentiality of documents suitable for disclosing know-how, transport information, commercial information and corporate transactions.
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Diligence
The relationship between PE – PRAGMA ETIMOS SRL and its employees is based on mutual trust: employees are, therefore, required to work to promote the interests of the company, in compliance with the values set out in this Code.
The Recipients must refrain from any activity that may constitute a conflict with the interests of PE – PRAGMA ETIMOS SRL, renouncing the pursuit of personal interests in conflict with the legitimate interests of the Company.
In cases where the possibility of the existence of a conflict of interest can be identified, the Recipients are required to contact, without delay, their hierarchical superior so that the company can assess, and possibly authorize, the potentially conflicting activity.
In the event of a breach, the Company will take all appropriate measures to put an end to the conflict of interest, reserving the right to act for its own protection.
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Loyalty
PE – PRAGMA ETIMOS SRL and the Recipients are committed to fair competition, in compliance with national and EU legislation, in the awareness that virtuous competition is a healthy incentive for innovation and development processes, as well as protecting the interests of consumers and the community.
Relations with employees and collaborators
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Personnel selection
The evaluation and selection of personnel are carried out according to fairness and transparency, respecting equal opportunities in order to combine the needs of PE – PRAGMA ETIMOS SRL, with the professional profiles, ambitions and expectations of the candidates.
PE – PRAGMA ETIMOS SRL undertakes to adopt all useful measures to avoid any form of favoritism in the personnel selection process using objective and meritocratic criteria, respecting the dignity of candidates as well as in the interest of the good performance of the company.
The personnel hired, also through the implementation of this Code, receive clear and correct information about the roles, responsibilities, rights and duties of the parties.
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Personnel management
PE – PRAGMA ETIMOS SRL protects and enhances its human resources, committing itself to maintaining the necessary conditions for professional growth, knowledge and skills of each person, carrying out the appropriate training for professional updating and any initiative aimed at pursuing this purpose.
PE – PRAGMA ETIMOS SRL promotes the participation of workers in the life of the company, providing participatory tools capable of collecting the opinion and suggestions of workers, ensuring their widest participation.
Without prejudice to the maximum availability towards the Company, no worker may be obliged to perform tasks, services or favors not due on the basis of his or her employment contract and his or her role within the company.
The Company is firmly committed to combating episodes of mobbing, stalking, psychological violence and any discriminatory behaviour or behaviour that is detrimental to the dignity of the person inside and outside the company premises.
Relations between employees must be carried out with loyalty, fairness and mutual respect, in compliance with the values of civil coexistence and the freedom of people.
Working Environment
PE – PRAGMA ETIMOS SRL is committed to offering its staff a healthy, safe working environment that respects the dignity of workers.
Safety in the workplace is ensured both by rigorously implementing the provisions of the law in force, and by actively promoting the culture of safety through specific training programs. Staff training is a central element of the management system adopted.
PE – PRAGMA ETIMOS SRL protects the health of its workers, also ensuring compliance with hygiene and health prevention standards.
Business Management
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Compliance with internal procedures
PE – PRAGMA ETIMOS SRL believes that management efficiency and a culture of control are essential elements for the achievement of objectives.
Recipients are required to strictly comply with the company’s internal procedures and instructions.
Recipients must act according to their respective authorization profiles and must maintain all appropriate documentation to keep track of the actions taken on behalf of the company.
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Accounting management
In accounting management, the Recipients are required to act in compliance with the principles of truthfulness, accuracy and transparency, so that the reputation of PE – PRAGMA ETIMOS SRL is protected both internally and externally.
Compliance with these principles also allows the company to plan its operational strategies based on its real economic and financial situation.
All items reported in the accounts must therefore be supported by complete, clear and valid documentation, avoiding any form of omission, falsification and/or irregularity.
In the case of assets or economic items based on valuations and estimates, their recording must be based on criteria of reasonableness and prudence.
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Asset protection
The Recipients carry out their functions by trying to rationalise and contain the use of company resources.
The Recipients are required to correctly apply the provisions relating to security to protect the hardware devices from unauthorized access, which could seriously harm the rights to the protection of personal data of the staff and customers of PE – PRAGMA ETIMOS SRL.
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Communication
PE – PRAGMA ETIMOS SRL provides Stakeholders with suitable communication tools through which they can interact with the company to submit requests, ask for clarifications or make complaints.
PE – PRAGMA ETIMOS SRL promotes effective corporate communication capable of putting the company in contact with civil society, in order to understand the demands, needs and requirements of the community and to spread its values and mission.
The information disclosed to Stakeholders is complete and accurate so that recipients can make correct and informed decisions.
The advertising promotion of PE – PRAGMA ETIMOS SRL respects ethical values, protecting minors and repudiating vulgar or offensive messages.
External Relations
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Relations with Authorities and Public Administrations
Relations with the Authorities and the Public Administration must be based on the utmost clarity, transparency and collaboration, in full compliance with the law and according to the highest moral and professional standards.
Recipients, unless expressly authorised, may not interact in the name and on behalf of PE – PRAGMA ETIMOS SRL with the Authorities and the Public Administration.
In relations with Public Officials, Public Service Officers, and the Public Administration in general, the Authorized Recipients shall comply with the highest levels of fairness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for themselves or for PE – PRAGMA ETIMOS SRL.
In this regard, the Authorised Recipients will be required to strictly comply with the provisions of this Code, as well as, more generally, with the provisions of the directives issued by the management of PE – PRAGMA ETIMOS SRL.
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Relations with political organizations and trade unions
PE – PRAGMA ETIMOS SRL does not favour or discriminate against any political or trade union organisation.
The Company refrains from making any undue contribution in any form to political parties, trade unions or other social formations, except for specific exceptions and in any case always within the limits of what is permitted by the regulations in force.
Recipients are required to refrain from any direct, indirect or false pressure on politicians or trade union representatives.
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Relations with customers and suppliers
The Recipients deal with third parties with courtesy, competence and professionalism, in the belief that the protection of the company’s image and reputation depends on their conduct and consequently the achievement of the company’s objectives.
In particular, the Recipients must refrain from any form of unfair or deceptive behaviour that may lead customers or suppliers to rely on unfounded facts or circumstances.
The Recipients are required to constantly strive to offer punctual and high-quality services to customers, trying to limit any form of inefficiency or delay in order to maximize customer satisfaction.
Relations with suppliers are based on loyalty, fairness and transparency.
The choice of suppliers is made on the basis of objective criteria of cost-effectiveness, opportunity and efficiency.
The choice of suppliers on purely subjective and personal grounds or, in any case, by virtue of interests in conflict with those of the company is precluded.
The Recipients must put in place every possible control so that suppliers and customers are also able to comply with the fundamental ethical principles set out in this Code.
Internal control system
Compliance with the provisions of this Code is entrusted to the prudent, reasonable and careful supervision of each of the Recipients, within the scope of their respective roles and functions within the company.
All Recipients are invited to report to their direct superiors the facts and circumstances that may be in conflict with the principles and provisions of this Code.
The management of PE – PRAGMA ETIMOS SRL and the bodies in charge of this purpose shall take all necessary measures to put an end to the violations, being able to resort to any disciplinary measure in compliance with the law and workers’ rights, including trade union rights.
Guidelines of the sanctioning system
The internal control system is oriented towards the adoption of tools and methodologies aimed at countering potential corporate risks, in order to ensure compliance not only with the law, but also with internal provisions and procedures.
In fact, the violation of the principles set out in the Code and in the procedures indicated in the internal controls compromises the relationship of trust between the Company and its directors, employees, consultants, collaborators in various capacities, customers, suppliers, commercial and financial partners.
Such violations will therefore be immediately prosecuted by PE – PRAGMA ETIMOS SRL in an incisive and timely manner, through the adoption of appropriate and proportionate disciplinary measures.
The effects of violations of the Code of Ethics and internal protocols must be taken into account by all those who, for any reason, have relations with PE – PRAGMA ETIMOS SRL. Depending on the seriousness of the conduct carried out by the person involved in one of the illegal activities provided for by the Code, PE – PRAGMA ETIMOS SRL will take the appropriate measures without delay, regardless of whether criminal prosecution is carried out by the judicial authorities.
Without prejudice to the above, conduct in violation of the Code of Ethics constitutes:
o serious non-compliance for employees (blue-collar workers, white-collar workers, middle managers and managers), with the sanctions, applied according to the severity, provided for by the CCNL of the category (verbal reprimand, written reprimand, fine not exceeding three hours of pay, suspension from work and pay up to a maximum of three working days, dismissal for just cause or justified reason); in the event that the criminal prosecution is pending or in the event of the execution of a measure restricting personal liberty taken against the employee, before adopting the disciplinary measure, the sanction of suspension from service and pay may be adopted, for the duration corresponding to the outcome of the criminal prosecution or until the end of the duration of the measure restricting personal freedom;
or just cause for revocation of the mandate of the directors;
o cause for immediate termination of the relationship, in the most serious cases, for external and parasubordinate collaborators;
or cause for immediate termination of the relationship, in the most serious cases, for suppliers, contractors and subcontractors.
The identification and application of penalties will always take into account the general principles of proportionality and appropriateness in relation to the alleged infringement.
In all the above cases, PE – PRAGMA ETIMOS SRL also reserves the right to take all the actions it deems appropriate for compensation for the damage suffered as a result of the conduct in violation of the Code of Ethics.