The Legal Representative of Intellitronika srl (hereinafter also \u201cIntellitronika\u201d) has adopted this Code of Ethics and Professional Conduct, which reflects the Company\u2019s commitment to:<\/p>\n\n\n\n
This document, which forms an integral part of the Organization, Management and Control Model pursuant to Legislative Decree 231\/01, defines the values and principles of conduct relevant to the proper functioning, reliability, compliance with laws and regulations, as well as the image of Intellitronika. <\/p>\n\n\n\n
It sets out the rights, duties and responsibilities of stakeholders internal and external to the Company, beyond and irrespective of the provisions established by law.<\/p>\n\n\n\n
All persons acting to achieve the Company\u2019s objectives, whether in senior positions or as employees, are required to comply with this Code of Ethics in the conduct of business and corporate activities.<\/p>\n\n\n\n
This Code also applies, where relevant, to collaborators and external consultants acting in the name and on behalf of Intellitronika.<\/p>\n\n\n\n
Addressees must conduct themselves in accordance with the fundamental principles of honesty, moral integrity, fairness, transparency, objectivity and respect for individual dignity, in pursuing corporate objectives and in all relationships with persons and entities internal and external to the Company.<\/p>\n\n\n\n
Under no circumstances may the pursuit of Intellitronika\u2019s interests justify conduct that does not comply with honest standards of behavior. <\/p>\n\n\n\n
Therefore, Intellitronika reserves the right not to establish or continue any relationship with anyone who adopts conduct inconsistent with the provisions of the Code of Ethics.<\/p>\n\n\n\n
The Code of Ethics is an integral part of the Organization, Management and Control Model adopted by Intellitronika for the purposes of Legislative Decree 231\/01 and includes, inter alia, the general principles and behavioral rules to which the Company attributes positive ethical value, guiding the addressees of the Code as to the conduct to be followed and avoided, while identifying responsibilities and any consequences in terms of sanctions. <\/p>\n\n\n\n
The Organizational Model and the internal procedures adopted by Intellitronika for the conduct of its activities in general, and in particular those referred to in the following chapters, comply with the rules contained in this Code.<\/p>\n\n\n\n
Intellitronika srl was founded in 2010, and from the outset we achieved significant results in the fields of mobile data management, personnel and vehicle localization, and territorial control, enabling us over the years to reach very high standards of specialization.<\/p>\n\n\n\n
It operates in the situation management sector, designing and delivering solutions for emergency professionals and the business world. Our DNA combines the nature of an ICT company strongly focused on community-oriented solutions with the capabilities of a software house engaged in the research and development of high-impact technological IoT solutions.<\/p>\n\n\n\n
It is part of ITK Group, which has been operating in the innovation sector for over 30 years, developing solutions for major public entities and large private groups. ITK Group, like Intellitronika itself, can rely on a global network of partners, collaborators and clients which today represents our strength and gives us a stability and vision for the future that few companies like ours can claim.<\/p>\n\n\n\n
For details, please refer to the corporate purpose as stated in the Chamber of Commerce register extract.<\/p>\n\n\n\n
As of the date of issue of this Code of Ethics, Intellitronika holds the following management system certifications issued by an Independent Third Party:<\/p>\n\n\n\n
Intellitronika aims to provide Customers with safe, cost-effective and reliable solutions.<\/p>\n\n\n\n
Our commitment is to leave every place in which we operate in better condition, both in terms of aesthetic quality and the quality of life of those who live and work there.<\/p>\n\n\n\n
For this reason, we give absolute priority to safe working conditions, environmental protection, respect for our employees and the communities we affect, and to building lasting relationships of trust also with our business partners.<\/p>\n\n\n\n
Creating value and satisfying the explicit and implicit needs of Customers, employees, suppliers and the communities concerned constitute Intellitronika\u2019s primary mission, while respecting the interests and expectations of all stakeholder categories.<\/p>\n\n\n\n
Intellitronika srl is committed to the continuous improvement of the technologies at its disposal and to the search for innovative solutions in order to offer Customers first-rate service. For Intellitronika, Customer satisfaction lies at the heart of its business. <\/p>\n\n\n\n
All Intellitronika activities are carried out with strict attention to compliance with laws, regulations and the internal procedural system.<\/p>\n\n\n\n
The addressees of this Code of Professional Conduct are required to comply with the laws and, more generally, with the regulations in force in the country where they operate.<\/p>\n\n\n\n
Addressees are also required to comply with company regulations insofar as these implement legal obligations.<\/p>\n\n\n\n
Addressees are required to comply with ethical and professional rules, with particular reference to the duties of diligence and competence applicable to transactions carried out on behalf of the Company.<\/p>\n\n\n\n
Addressees are also required to comply with company regulations, which set out in detail the methods for pursuing objectives in accordance with the adopted ethical and behavioral principles, as an implementation of ethical or professional obligations.<\/p>\n\n\n\n
Addressees are required to observe the duty of transparency, understood as clarity, completeness and relevance of information, avoiding misleading situations in transactions carried out on behalf of the Company.<\/p>\n\n\n\n
Addressees are required to comply with company regulations as an implementation of the principle of transparency.<\/p>\n\n\n\n
No confidential information acquired or processed by Addressees in the course of, or in connection with, their activities may be used, communicated to third parties or disclosed for purposes other than institutional ones. To this end, Intellitronika has prepared and required its employees to sign a confidentiality undertaking. <\/p>\n\n\n\n
All those who collaborate with Intellitronika in any capacity have the right to be treated equally and with respect. Intellitronika does not discriminate against persons on the grounds of race, place of birth and ethnic origin, skin color, disability, age, sex, sexual identity, religious belief, health condition and sexual orientation, or on any other discriminatory ground, in compliance with the law. <\/p>\n\n\n\n
Everyone is guaranteed a working environment free from racism and discrimination. Company decisions are taken on the basis of qualifications, experience and objective professional criteria. <\/p>\n\n\n\n
A Gender Equity Committee is also in place. <\/p>\n\n\n\n
The information disseminated by Intellitronika is complete, transparent, comprehensible and accurate, so as to enable addressees to make informed decisions regarding relationships to be established with external parties.<\/p>\n\n\n\n
Employees and Collaborators, whose physical and moral integrity is considered a primary value, are guaranteed working conditions that respect individual dignity, in safe and healthy workplaces.<\/p>\n\n\n\n
Intellitronika constantly strives to ensure that its economic and financial performance safeguards and increases the value of the company, so as to adequately remunerate the risk undertaken by investors and likewise create financial resources for the company\u2019s development.<\/p>\n\n\n\n
Intellitronika recognizes the need to protect individual freedom in all its forms as a constitutionally guaranteed right, and rejects every manifestation of violence and exploitation, especially where aimed at limiting personal freedom and undermining human dignity.<\/p>\n\n\n\n
For this reason, Intellitronika has also decided to adopt whistleblowing reporting procedures pursuant to Legislative Decree 24\/2023. <\/p>\n\n\n\n
In carrying out their respective activities, the Addressees of the Code of Ethics shall comply with:<\/p>\n\n\n\n
All Addressees shall refrain from:<\/p>\n\n\n\n
Intellitronika srl safeguards and promotes the value and development of human resources as a factor of investment, protection and success for the Company itself, in order to foster their full professional development on the basis of merit criteria.<\/p>\n\n\n\n
Recruitment, transfer and\/or promotion practices must in no way be influenced by offers and\/or promises of money, goods, benefits, advantages or services of any kind.<\/p>\n\n\n\n
In managing relationships involving hierarchical structures, Intellitronika requires authority to be exercised fairly and correctly, prohibiting any behavior that may be considered harmful to the dignity and autonomy of employees.<\/p>\n\n\n\n
Any form of discrimination is avoided and, in particular, discrimination based on race, nationality, sex, age, disability, sexual orientation, political or trade union opinions, philosophical beliefs or religious convictions towards any person internal or external to the Company. <\/p>\n\n\n\n
Intellitronika srl undertakes to protect the physical and moral integrity of its collaborators, guaranteeing the right to working conditions that respect personal dignity.<\/p>\n\n\n\n
No form of undeclared work is tolerated; this includes, in addition to the mere absence of formal regularization of an employment relationship, any use of work performance not framed within a contractual and regulatory arrangement consistent with that of the relevant country.<\/p>\n\n\n\n
Employee privacy is protected in accordance with Regulation (EU) 2016\/679.<\/p>\n\n\n\n
Upon entering into the employment relationship, each employee must receive accurate information relating to:<\/p>\n\n\n\n
Personnel must avoid engaging in or facilitating transactions that are in conflict of interest\u2014actual or potential\u2014with the Company, as well as activities that may interfere with the ability to make impartial decisions in the best interests of the Company and in full compliance with the principles of this Code of Ethics. <\/p>\n\n\n\n
Personnel must not have financial and\/or personal interests in the selection of a supplier, in a competing company or in a client, and may not perform work activities that may give rise to a conflict of interest, even if only potential. <\/p>\n\n\n\n
Relations with suppliers are based on the principles of transparency, loyalty, integrity, confidentiality, diligence, professionalism and objectivity of judgment.<\/p>\n\n\n\n
The selection of suppliers and the purchase of goods and services are carried out by the relevant corporate functions on the basis of objective assessments concerning legality, expertise, competitiveness, quality, fairness, respectability, reputation and price.<\/p>\n\n\n\n
Intellitronika\u2019s suppliers must not be involved in unlawful activities and must guarantee their employees working conditions based on respect for fundamental human rights, international conventions and applicable laws. <\/p>\n\n\n\n
In particular:<\/p>\n\n\n\n
Intellitronika recommends that its suppliers refrain from offering goods or services, in particular in the form of gifts, to the Company\u2019s collaborators where such offers exceed normal courtesy practices, and prohibits its employees from offering goods or services to personnel of other companies or entities in order to obtain confidential information or significant direct or indirect benefits for themselves or for the Company.<\/p>\n\n\n\n
In the event of a breach of the principles of legality, fairness, transparency, confidentiality and respect for human dignity, Intellitronika is entitled to adopt appropriate measures, up to and including the possible termination of the relationship with the supplier.<\/p>\n\n\n\n
In any event, Intellitronika shall be held harmless from any form of liability attributable to third parties and\/or suppliers, however understood or designated.<\/p>\n\n\n\n
Within the framework of relations with external Consultants and other collaborators, however defined, Directors and Employees are required to:<\/p>\n\n\n\n
It is not permitted to carry out services or make payments in favor of collaborators, consultants or other third parties acting on behalf of the Company that are not adequately justified within the contractual relationship established with them or in relation to the type of assignment to be performed.<\/p>\n\n\n\n
Breach of the principles of legality, fairness, transparency, confidentiality and respect for human dignity constitutes just cause for termination of contractual relationships.<\/p>\n\n\n\n
Professionalism, competence, availability, respect and fairness represent the guiding principles and the style of conduct to be followed in relations with customers.<\/p>\n\n\n\n
It is therefore essential that relations with customers be based on full transparency and fairness, compliance with the law and independence from any form of influence, whether internal or external.<\/p>\n\n\n\n
Contracts and communications to customers must be:<\/p>\n\n\n\n
Within commercial relations with customers, it is prohibited to engage in conduct that may undermine consumer trust.<\/p>\n\n\n\n
Intellitronika aims to protect the value of fair competition by refraining from collusive and predatory conduct.<\/p>\n\n\n\n
The Company and its collaborators must comply with the principles and rules of free competition and must not violate applicable laws on competition, antitrust and consumer protection.<\/p>\n\n\n\n
It is therefore prohibited to engage in any conduct that violates the normal and free exercise of trade and industry and that, as such, undermines commercial trust and good faith in business.<\/p>\n\n\n\n
Within the framework of fair competition and protection of the end user, the Company and its collaborators undertake not to infringe third-party intellectual property rights and to comply with the regulations protecting distinctive signs of intellectual works and\/or industrial products (trademarks, patents), implementing controls to ensure full compliance with the applicable industrial property regulations.<\/p>\n\n\n\n
Relations with Public Administration and Public Institutions, however named (including, by way of example and not limitation, Ministries and their peripheral offices, public bodies, entities and companies operating in the public services sector, territorial entities, local authorities, the Data Protection Authority), are conducted by Company Representatives or by persons duly authorized, or by individuals formally delegated by them, in compliance with the provisions of this Code and the Articles of Association, with particular regard to the principles of fairness, transparency and efficiency.<\/p>\n\n\n\n
In particular, by way of example only:<\/p>\n\n\n\n
The proper functioning of the Public Function, in particular the Judicial Function, is also ensured through the prohibition imposed on all persons subject to this Code of Ethics from undertaking, directly or indirectly, any unlawful action that may favor or harm one of the parties involved in civil, criminal or administrative proceedings.<\/p>\n\n\n\n
In particular, it is prohibited to exert undue pressure (offers or promises of money or other benefits) or unlawful coercion (violence or threats) in order to induce a person called to give statements before the judicial authority in criminal proceedings to refrain from making statements or to make false statements, where such person has the right to remain silent.<\/p>\n\n\n\n
In general, it is mandatory to behave in a correct, transparent and cooperative manner, in compliance with the law and internal procedures, in all activities aimed at the preparation of financial statements, in order to provide a true and fair view of the Company\u2019s financial and economic position.<\/p>\n\n\n\n
Every transaction or operation must be accurate, verifiable and legitimate.<\/p>\n\n\n\n
This means that each action and transaction must be properly recorded in accounting records and supported by appropriate documentation, in order to allow controls to be carried out, to identify the various levels of responsibility and to accurately reconstruct the transaction.<\/p>\n\n\n\n
All persons who, for any reason, including merely as providers of data, are involved in the preparation of financial statements and similar documents, or in any case documents representing the Company\u2019s financial position, as well as in particular the Sole Director and those in top positions:<\/p>\n\n\n\n
Intellitronika intends to ensure the dissemination and observance of conduct principles aimed at safeguarding share capital and protecting creditors and third parties entering into relations with the Company, in full compliance with the law.<\/p>\n\n\n\n
In particular, the following are expressly prohibited:<\/p>\n\n\n\n
Documents, work tools, equipment and facilities, and any other tangible or intangible assets (including intellectual property rights and trademarks) owned by Intellitronika srl shall be used exclusively for the achievement of corporate purposes, in accordance with the procedures established by the Company; they may not be used for unlawful purposes and must be used and safeguarded with the same diligence as one\u2019s own property. Any unlawful use may be subject to sanctions, including disciplinary measures, regardless of whether it constitutes a criminal offence under applicable law. <\/p>\n\n\n\n
The Company protects the personal data of all individuals who interact with it, in accordance with applicable data protection regulations.<\/p>\n\n\n\n
Information acquired in the course of one\u2019s duties, which also constitutes an asset of the Company, is subject to legal provisions and confidentiality obligations. These obligations must also be observed after termination of the relationship with the Company, in accordance with applicable regulations. <\/p>\n\n\n\n
IT and telematic tools (such as telephones and fax machines, email, Internet, intranet and, in general, hardware and software) made available to personnel are work tools and, therefore, must be used exclusively for business purposes: this applies both to the use of personal computers and to other tools, programs and services.<\/p>\n\n\n\n
Each employee is also required to make the necessary effort to prevent the possible commission of offences through the use of IT tools.<\/p>\n\n\n\n
In particular, personnel are prohibited from:<\/p>\n\n\n\n
Personnel may not upload onto company systems software that is borrowed, unauthorized or lacking the necessary licenses, nor is it permitted to make unauthorized copies of licensed software for personal, company or third-party use.<\/p>\n\n\n\n
Intellitronika conducts its activities in full compliance with applicable anti-money laundering regulations and the provisions issued by the competent authorities.<\/p>\n\n\n\n
The Company adopts the principle of maximum transparency in commercial transactions and implements the most appropriate tools to prevent and combat the phenomena of receiving stolen goods, money laundering and the use of money, assets or other benefits of illicit origin.<\/p>\n\n\n\n
Personnel must never engage in or be involved in activities that may involve money laundering (i.e., the acceptance or processing) of proceeds from criminal activities in any form or manner.<\/p>\n\n\n\n
The Director, employees and collaborators must carry out prior verification of available information (including financial information) on business counterparties, consultants and suppliers, in order to ascertain their moral integrity, reliability and the legitimacy of their activities before entering into business relationships; they are required to strictly comply with laws, company policies and procedures in any financial transaction in which they are involved, ensuring full traceability of incoming and outgoing financial flows and full compliance with applicable anti-money laundering regulations.<\/p>\n\n\n\n
It is not permitted to offer or receive gifts or benefits that may be interpreted as exceeding normal business courtesy practices or that may be considered as a means to obtain preferential treatment in the performance of work activities. <\/p>\n\n\n\n
No form of corrupt conduct towards public officials, civil servants, employees of public administration, authorities or public institutions is tolerated, in any form whatsoever. The rules governing the Company\u2019s operational activities under national legislation must be strictly observed and complied with. The aforementioned rules may not be circumvented by resorting to activities carried out by third parties and\/or by procedures designed to bypass such rules. <\/p>\n\n\n\n
Gifts also include benefits such as the offer of participation in seminars or training courses, including travel and accommodation, aimed at encouraging the use of products or services.<\/p>\n\n\n\n
Intellitronika srl establishes that the recipients of this Code of Ethics must refrain from offering and\/or promising to third parties sums of money or other benefits in any form or manner, even indirectly, in order to promote or favor the Company\u2019s interests, even if subject to unlawful pressure.<\/p>\n\n\n\n
It also establishes that they may not accept for themselves or for others such sums and\/or benefits in order to promote or favor third-party interests in dealings with Intellitronika.<\/p>\n\n\n\n
Gifts of significant value are not permitted; if of modest value, they must be attributable solely to acts of mutual courtesy within the framework of proper business relationships and in compliance with sector regulations and internal policies. Furthermore, they are prohibited from presenting or disseminating untrue information or omitting information or concealing data in direct or indirect violation of regulatory principles and internal procedural rules, in such a way as to mislead third-party recipients of such information. Any actions identified as being in conflict with the ethical and behavioral principles set out in this Code must be promptly reported to the Supervisory Body. <\/p>\n\n\n\n
Personnel and the recipients of the Code of Ethics, in their relations with the Supervisory Body, must:<\/p>\n\n\n\n
Intellitronika srl is committed to pursuing the objectives of improving workers\u2019 health and safety as an integral part of its activities and as a strategic commitment in relation to the Company\u2019s broader objectives.<\/p>\n\n\n\n
To this end, the Company:<\/p>\n\n\n\n
Personnel must take care of their own health and safety and that of other persons present in the workplace, who may be affected by their actions or omissions, in accordance with the training, instructions and means provided by the employer.<\/p>\n\n\n\n
For this reason, the use of drugs, alcohol abuse or the use of illegal substances in the workplace will not be tolerated.<\/p>\n\n\n\n
Intellitronika aims to ensure full compatibility of its activities with the territory and the surrounding environment.<\/p>\n\n\n\n
To this end, it undertakes to carry out its activities in full respect of the environment, understood in its broadest sense, in particular:<\/p>\n\n\n\n
Confidential information means any type of information belonging to Intellitronika srl that must not be disclosed to the public or to unauthorized third parties, also in accordance with an internal classification system of confidentiality.<\/p>\n\n\n\n
Confidential information includes any information produced by Intellitronika and\/or obtained confidentially from third parties and bound by a non-disclosure agreement. Examples of confidential information include intellectual property, trade secrets, employee-related information, legal documents, and information concerning clients and suppliers. <\/p>\n\n\n\n
Employees are prohibited from disclosing confidential information to persons who are not authorized recipients, unless authorized or legally required. This rule also applies to confidential information provided by suppliers and clients. Employees undertake to maintain the utmost confidentiality even after termination of their employment relationship with Intellitronika. <\/p>\n\n\n\n
Employees and recipients must exercise the utmost care to avoid improper use of confidential information and\/or its unintentional disclosure to third parties. <\/p>\n\n\n\n
Therefore, it is necessary to:<\/p>\n\n\n\n
Intellitronika rejects all forms of terrorism and any anti-democratic and violent form of political coercion. <\/p>\n\n\n\n
It intends to adopt, within its activities, appropriate measures to prevent the risk of involvement in acts of terrorism, thereby contributing to the promotion of democracy and peace among peoples.<\/p>\n\n\n\n
To this end, the Company undertakes not to establish any employment or commercial relationship with individuals or entities involved in acts of terrorism; not to finance or otherwise facilitate any of their activities; and to report to the competent authorities any events related to such acts, if aware of them.<\/p>\n\n\n\n
Intellitronika does not provide contributions of any kind, directly or indirectly, to political parties, movements, committees or political and trade union organizations, nor to their representatives and candidates, except in the forms and manner permitted by applicable law.<\/p>\n\n\n\n
Intellitronika\u2019s corporate strategy is oriented towards consolidating and expanding its range of services through targeted research and technological development programs, as well as strengthening its position in the most profitable markets by intensifying commercial activities. In the long term, this will ensure an optimal balance between opportunities and risks for stakeholders. <\/p>\n\n\n\n
In light of this, Intellitronika considers corporate governance, risk and opportunity management, risk control (risk management), and regulatory compliance as areas of paramount importance, to be addressed through integrated approaches.<\/p>\n\n\n\n
This ensures, in all circumstances, compliance with applicable mandatory requirements. Intellitronika pursues its business objectives with responsibility and efficiency and ensures that the company is not exposed to uncontrolled risks. <\/p>\n\n\n\n
Responsible management focused on long-term success is an integral part of Intellitronika\u2019s corporate culture. Company functions operate under the strict supervision of top management and are guided by best practice principles. <\/p>\n\n\n\n
As part of the activities aimed at adapting its organizational model to the requirements set out in Legislative Decree 231\/01, Intellitronika has established a single-member Supervisory Body (\u201cSB\u201d), whose function is to verify the proper functioning of the organizational, management and control model and compliance, by the recipients, with the rules contained in the Code of Ethics, also proposing any updates. <\/p>\n\n\n\n
This Body undertakes to report periodically to the Sole Director on the activities carried out.<\/p>\n\n\n\n
Personnel and recipients may contact the Supervisory Body at any time, either in writing (by email at: odv@intellitronika.com) or verbally, also for the purpose of requesting clarifications and\/or information, for example:<\/p>\n\n\n\n
Information that may give rise to suspicion of violations, including potential ones, of Model 231 must be reported immediately and mandatorily to the SB, including but not limited to:<\/p>\n\n\n\n
Information relating to the activities of Intellitronika srl that may be relevant to the Supervisory Body\u2019s functions and areas of responsibility must also be mandatorily and immediately communicated to the SB, including but not limited to:<\/p>\n\n\n\n
Recipients may contact the Supervisory Body at any time by email at: odv@intellitronika.com or verbally, including anonymously, to request clarifications and\/or information, for example:<\/p>\n\n\n\n
Whistleblowers may at any time report to the Supervisory Body detailed events concerning unlawful conduct relevant under Legislative Decree 231\/01 and applicable mandatory regulations: <\/p>\n\n\n\n
Compliance with this Code of Ethics by employees and collaborators, as well as their commitment to observe the general duties of loyalty, fairness and performance of the employment contract in good faith, shall be considered an essential part of contractual obligations, also pursuant to and for the purposes of Article 2104 of the Italian Civil Code. <\/p>\n\n\n\n
Conduct by employees in violation of the behavioral or procedural rules contained in this Code of Ethics shall be considered disciplinary offences subject to sanctions in accordance with applicable regulations.<\/p>\n\n\n\n
Compliance with the Code of Ethics by third parties (suppliers, consultants, subcontractors, etc.) constitutes fulfilment of the duties of diligence and good faith in negotiations and in the performance of contracts with the Company.<\/p>\n\n\n\n
Violations committed by third parties shall be subject to sanctions in accordance with the provisions set out in the relevant assignments and contracts.<\/p>\n\n\n\n
Intellitronika srl shall adopt the contents of this Code of Ethics, establishing rules for its dissemination among employees through publication on the company website, sharing on the corporate intranet and posting in accessible notice boards. <\/p>\n\n\n\n
This Code of Ethics shall also apply in countries other than Italy, where, if necessary, it will be adapted to the laws, regulations and values of the country in which the Company operates, in compliance with fundamental human rights and international conventions.<\/p>\n\n\n\n
Serious and repeated violations of the Code of Ethics by recipients undermine the relationship of trust with the Company and may result in disciplinary sanctions, compensation for damages and, in cases of serious breach, termination of employment.<\/p>\n\n\n\n
The term \u201cserious breaches\u201d refers, for the purposes of this Code, to all persistent violations resulting in sanctions against the Company.<\/p>\n\n\n\n
Article 6, paragraph 2, letter e) and Article 7, paragraph 4, letter b) of Legislative Decree 231\/01 establish, as a condition for the effective implementation of the organizational, management and control model, the introduction of a disciplinary system capable of sanctioning failure to comply with the measures set out in the Model. The establishment of an effective disciplinary system is an essential prerequisite for the validity of Model 231. <\/p>\n\n\n\n
The sanctions provided for by the disciplinary system shall be applied to any violation of the provisions contained in Model 231, regardless of the initiation or outcome of any criminal proceedings that may be brought by the judicial authority if the conduct in question constitutes a criminal offence under Legislative Decree 231\/01.<\/p>\n\n\n\n
Intellitronika has adopted this Disciplinary System aimed at sanctioning violations of the principles, rules and measures set out in the Model and its related Protocols, in compliance with national collective labor agreements and applicable laws and regulations.<\/p>\n\n\n\n
On the basis of this Disciplinary System, violations of Model 231 and its related protocols are subject to sanctions:<\/p>\n\n\n\n
Any violation of the individual provisions and behavioral rules set out in Model 231 by employees of Intellitronika, subject to the applicable national collective labor agreement, shall always constitute a disciplinary offence.<\/p>\n\n\n\n
The procedures contained in Model 231, the non-compliance with which is subject to sanctions, are communicated to all employees through the tools provided in the General Part of the organizational, management and control model of Intellitronika srl. <\/p>\n\n\n\n
For each violation of Model 231 identified by the Supervisory Body, disciplinary action shall be initiated to ascertain responsibility for the violation. In particular, during the assessment phase, the employee will be formally notified in advance of the charges and granted a reasonable period to present their defense and justifications. Once responsibility has been established, a disciplinary sanction proportionate to the severity of the violation will be imposed on the offender. <\/p>\n\n\n\n
For employees, compliance with the rules of the Code of Ethics is an essential part of contractual obligations pursuant to Articles 2104, 2105 and 2106 of the Italian Civil Code.<\/p>\n\n\n\n
The sanctions that may be imposed on employees, in accordance with Article 7 of Law No. 300 of 30 May 1970 (so-called \u201cWorkers\u2019 Statute\u201d) and any applicable special regulations, are those provided for by law, as well as by the sanctioning system set out in employment contracts, namely: <\/p>\n\n\n\n
The type and extent of each of the aforementioned sanctions shall also be applied taking into account:<\/p>\n\n\n\n
It is understood that all provisions and guarantees provided for by law and by employment contracts regarding disciplinary proceedings shall be observed; in particular, the following shall be respected:<\/p>\n\n\n\n
With regard to the ascertainment of infringements, disciplinary proceedings and the imposition of sanctions, the powers already granted, within the limits of their respective delegations and responsibilities, to hierarchical managers shall remain valid.<\/p>\n\n\n\n
Intellitronika intends to make its employees aware of the provisions and behavioral rules contained in the Model, the violation of which constitutes a disciplinary offence, as well as of the applicable sanctions, taking into account the seriousness of the infringements.<\/p>\n\n\n\n
Violations of the principles and measures provided for in Model 231 adopted by the Company committed by the Legal Representative must be promptly reported by the SB, which shall assess the actions to be taken as appropriate.<\/p>\n\n\n\n
Any violation by Suppliers, Subcontractors, Professionals or External Collaborators of the provisions and rules of conduct laid down in Model 231 applicable to them, or any commission by them of the offences contemplated by Legislative Decree 231\/01, shall, where possible, be sanctioned in accordance with the specific clauses of the relevant contracts. <\/p>\n\n\n\n
Such clauses may provide, by way of example only, for the right to terminate the contract and\/or the payment of penalties (in compliance with the clauses specifically included in the relevant contracts), without prejudice to any claim for damages should such conduct cause actual damage to the Company.<\/p>\n\n\n\n
Should the whistleblower protection measures be violated and the identity of the whistleblower be made public in the absence of the circumstances provided for by law, or should retaliatory or discriminatory acts, direct or indirect, be adopted against the whistleblower for reasons directly or indirectly connected with the report, sanctions shall be applied to those responsible for such violations on the basis of the criteria set out in the preceding paragraphs of this Chapter 10.<\/p>\n\n\n\n
Likewise, the sanctioning system indicated in the preceding paragraphs of this Chapter 10 shall apply to anyone who, with intent or gross negligence, makes reports that prove to be unfounded.<\/p>\n\n\n\n
This Code of Ethics is approved by the Sole Director of Intellitronika srl, who undertakes to make it known, for the purposes and effects of Legislative Decree 231\/01, to all Recipients. Any amendments and additions to the Code of Ethics must be promptly communicated to the Recipients. <\/p>\n\n\n\n
Intellitronika undertakes to ensure proper internal and external dissemination of the Code through:<\/p>\n\n\n\n
Management, in cooperation with the Supervisory Body, prepares and carries out periodic training initiatives on the principles of this Code and related matters.<\/p>\n\n\n\n
In contracts with Third-Party Recipients (also simply \u201cThird Parties\u201d), the introduction of clauses and\/or the signing of declarations is also provided for, both to formalize the commitment to comply with Model 231 and this Code and to regulate contractual sanctions in the event of breach of such commitment.<\/p>\n\n\n\n
The Legal Representative\/Sole Director is competent for any amendment and\/or addition to this Code of Ethics.<\/p>\n\n\n\n
In particular, additions and amendments may become necessary due to changes in the applicable legal framework or in the Company\u2019s internal organization.<\/p>\n\n\n\n
Initially, Employees, and subsequently new Employees, shall be required to sign a declaration stating that they have carefully examined, read and understood the Code of Ethics.<\/p>\n\n\n\n
Periodically and at its discretion, the Supervisory Body may require certain Employees to sign a declaration stating not only that they have carefully examined, read and understood the Code, but also that they always act in compliance with the principles set out in this Code of Ethics and that they are not aware of any violations thereof.<\/p>\n\n\n\n
In accordance with the general corporate policies, Intellitronika adopts its own or common policies and procedures. Employees are required to comply with the above-mentioned policies and procedures, in addition to those set out in this Code. <\/p>\n\n\n\n
For the purposes of this document, the following definitions shall apply:<\/p>\n\n\n\n
20 October 2025 <\/p>\n\n\n\n
<\/p>\n","protected":false},"menu_order":0,"template":"","meta":{"_acf_changed":false,"_links_to":"","_links_to_target":""},"class_list":["post-12723","legali","type-legali","status-publish","hentry"],"acf":[],"yoast_head":"\n