CODE OF ETHICS

For any report of critical situations, of violation or attempted violation of the code of ethics and of the Organization and Management Model, you can contact our Supervisory Body at the following email address: odv@minervagroupservice.it 

We are committed to ensuring the confidentiality of reports and to prohibit any form of retaliation against whistleblowers.


CODE OF ETHICS

For the prevention of criminal corporate liability in accordance with the Italian Legislative Decree n. 231 of 8 June 2001 ‚ÄúProvisions on the administrative  liabilities of legal entities, companies and associations also without legal corporate personality according to art. 11 of the Italian  law of 29 September 2000 n. 300.

 

Dear Customer,

Dear Collaborator,

Dear Supplier,

Dear Business Partner,

 

We have always operated in compliance with the principles of transparency, integrity, legality.

We want all those who entertain collaboration and supply relationships with us to commit to respecting the same principles which are mandatory for us.

 

Our business  context

We are a founding and participating company of Minerva Group Service (MGS) www.minervagroupservice.com  that is the hub of a network of controlled, participated and business partner companies.

Our  mission is to provide professional services to businesses (advisory, professional training, audit and business assurance).

 

Our commitment to crime prevention

By this Code of Ethics we expressly prohibit any behavior that could lead to the commission of the crimes referred to in Legislative Decree 231/01, even if this could imply a significant interest or advantage for our Company.

This code of ethics is referred to as an integral part of any contractual agreement.

This code of ethics is communicated to all our stakeholders and is available on our website www.alpemi.it

 

Our objectives for crime prevention and related behavior guidelines

 

Our commitment

We ask you to take particular care to avoid behaviors that, even in good faith, may constitute a risk of committing the offenses envisaged by Legislative Decree 231/01.

This with particular reference to the main crimes related to our business context.

For this purpose we ask you to respect the principles and guidelines below.

 

Our objective: to prevent fraud against the State or Public Administration

All public funds received by us must be managed in compliance with the principles of transparency, integrity and in strict compliance with the purposes for which they were received.

 

Our objectives: to prevent IT crimes and illegal data processing

All IT resources (IT services and IT infrastructure) must be used for lawful purposes just as the information through these processes must have lawful purposes.

We have adopted a specific policy for the management of information security in accordance with the ISO 27001 standard and a specific policy for the protection of personal data in accordance with the requirements of the GDPR and the ISO 27701 standard. These policies are an integral part of this code of ethics and are available on our website www.alpemi.it  

 

Our objectives: to prevent bribery crimes

No promises must be made and no undue inducements must made by third parties to make promises of utility that can be considered as attempts at bribery.

We have adopted a specific policy for antibribery in accordance with the ISO 37001 standard. This policy is  an integral part of this code of ethics and is available on our website www.alpemi.it

 

Our objectives: to prevent financial crimes

All our corporate financial resources, including incoming and outgoing flows, must be managed in compliance with the principles of transparency and traceability as well as the correct allocation of cost and revenue items.

All accounting records must comply with applicable legal requirements.

 

Our objectives: to prevent market abuse crimes

All information processed by us or processed on our behalf that can be used directly or indirectly for market abuse or insider trading.

All  classified information must be considered confidential and adequately protected.

 

Our objectives: to prevent Homicide and serious injuries through violation of the rules on Occupational Health and Safety crimes

All legal requirements regarding health and safety at work must be promptly respected by anyone who has collaborative relationships with us.

 

Our objectives: to prevent receiving stolen goods, laundering and using money, goods or utilities of illegal origin, as well as self-laundering crimes

Suppliers of critical goods and services or for significant amounts must be qualified in advance.

All supplies of critical goods and services or of significant amounts must be formalized and the related financial flows made traceable and allocated to specific cost centers.

We have adopted a specific Quality policy in compliance with the ISO 9001 standard. This policy forms an integral part of this code of ethics and is available on our website www.alpemi.it

 

Our objective: to prevent  Intellectual  Property  Rights  crimes

The intellectual property of third parties must be protected and respected.

 

Our objectives: to prevent false statement in Court

Collaboration with the judicial authorities must always be full and transparent.

In no case is it allowed to induce not to make statements or to make false statements.

 

Our objectives: to prevent crimes concerning  hiring illegal  not-EU foreign workers

All employees must be hired in compliance with applicable labor law regulations and in no case is the use of irregular personnel allowed. This also applies to employees and collaborators of our member companies or suppliers.

 

Our objectives: to prevent tax crimes

Tax declaration and related financial information must always be based on truthfulness and correctness criteria.


Our Organization and Management Model (MOG) for crime prevention

In order to prevent the commission of the offenses envisaged by Legislative Decree 231/01 we have adopted an Organization and Management Model (MOG).

Our Organization and Management Model has been integrated into the more general corporate management system and has been planned to consider aspects of Governance and Internal Control System, Risk Management aspects (with reference to the guidelines of the ISO 31000 standard) and Compliance aspects (with reference to the guidelines of the ISO 19600 standard).

We are committed to keep updated and continually improving our Organization and Management Model and to train and to make aware our stakeholders regarding its correct application.

We have also appointed a Supervisory Body with the task of supervising the adequacy and correct application of the Organization and Management Model.

 

The penalties

Violations of this Code of Ethics and of the Organization and Management Model imply the application of disciplinary measures, including the termination of existing contractual relationships.


Our contact channels and whistleblowing

For any report of critical situations, of violation or attempted violation of the code of ethics and of the Organization and Management Model, you can contact our Supervisory Body at the following email address: odv@minervagroupservice.it 

We are committed to ensuring the confidentiality of reports and to prohibit any form of retaliation against whistleblowers.

 

 

 

Alpemi Consulting