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Ethics Code


Annex A to the Organization, Management and Control Model of Redemption S.r.l.








Redemption S.r.l. (Tax Code and VAT No. 07059720966), with registered office at Vicolo Santa Maria alla Porta No. 1 in Milan (MI - 20123) (hereinafter, the “Company”), has adopted this Code of Ethics (hereinafter, the “Code of Ethics”), which, within the scope of the Company's activities, takes as its guiding principles compliance with the law and regulations of the countries in which the Company is active, within a framework of integrity, fairness and confidentiality.

The Code of Ethics also aims to reconcile maximizing competitiveness on the market with respect for competition regulations and to promote, from the point of view of social responsibility and environmental protection, the correct and functional use of company resources.

The Company undertakes to disseminate the Code of Ethics, to update it periodically and to provide any possible instrument that supports its full application.

Knowledge of the Code of Ethics and the related internal procedures is achieved, specifically, by posting appropriate documentation in an accessible place and through training and refresher programs for personnel that are managed by the departments responsible.

The contents of the Code of Ethics are also brought to the attention of all those with whom the Company has business relations. In the event of non-compliance with the principles set forth in the Code of Ethics and the laws and regulations in force, the Company shall not start or continue the relevant business relations.


The rules of the Code of Ethics apply, without exception, to all employees of the Company and to all those who, directly or indirectly, permanently or temporarily, establish relationships and connections or work to pursue its objectives (hereinafter the “Recipients”). The Recipients, moreover, are informed by the Company of the penalties provided for in the event of a violation of the Code of Ethics and on the methods and procedures for their imposition.

Recipients may ask their line managers or those who are responsible for monitoring compliance with the Code of Ethics for clarifications on its contents, on the related internal procedures and on the tasks assigned to them at any time.

The Recipients are therefore required to be aware of the contents of the Code of Ethics, to observe its principles and rules and to contribute to its implementation, as well as to adequately inform third parties about the obligations imposed by the Code of Ethics, to demand compliance with it and to take appropriate steps in the event of non-compliance.

Accordingly, Recipients who become aware of any flaws, violations or attempted violations are required to notify their line manager or those responsible for monitoring compliance with the Code of Ethics and the Model.


The Company's relations and conduct, at all levels, must be based on the principles of honesty, fairness, integrity, transparency and mutual respect.

The Company operates in compliance with the laws and regulations in force in the countries where it conducts its business, in accordance with the principles set out in the Code of Ethics and the Model.

Within the scope of their respective competences, therefore, the Recipients are required to know and observe the laws and regulations in force in all the countries in which the Company is active.

Those acting responsibly shall conduct all activities, both internal and external, based on the utmost loyalty and integrity, in good faith, establishing correct professional and commercial relations, and aiming to enhance and safeguard the Company's property.

This commitment must also apply to consultants, suppliers, customers and anyone who has relations with the Company.

In its relations with employees and all third parties, the Company avoids all forms of discrimination based on age, nationality, religious belief, political and trade union membership, language, gender or health status.

Accordingly, the Company manages its human resources with the goal of guaranteeing equal opportunities and encouraging the professional growth of each individual in compliance with the values of the Code of Ethics and current legislation protecting workers.

The Company recognizes that human resources are a fundamentally important factor for its own development; therefore, it guarantees a safe working environment that facilitates accomplishing work and that enhances the professional skills of each individual.

To this end, the Company aims to enhance the skills of its resources, providing them with suitable training, professional updating and development tools.

The working environment, inspired by respect, fairness and collaboration, must facilitate people's involvement and responsibility.

The management of human resources is based on respect for the personality and professionalism of each individual, guaranteeing their physical and moral integrity.

Staff, in turn, must always behave respectfully with those with whom they come into contact, treating everyone fairly and with dignity.

The Company rejects all forms of exploitation of workers.

Specifically, the Company rejects the exploitation of child labor, as well as the performance of any work that could endanger or interfere with the education of children, their health and their physical, mental, moral and social development.

The Company also condemns and rejects the employment of non-EU foreign workers whose presence on Italian soil is irregular because they do not have a residence permit or because they have an expired residence permit.

The Company carries out its activities in accordance with existing legislation on protecting working conditions. All Recipients, within the scope of their duties, undertake to perform their tasks, which are grounded in preventing risks and in protecting their health and safety, and the health and safety of their colleagues and third parties.

Relations between Company employees must be grounded on the principles of peaceful coexistence and must be conducted with mutual respect for the rights and freedom of individuals.

Relations between the different levels of responsibility must be conducted fairly and honestly.

Those responsible for the organizational units must exercise the powers connected to the mandate they received using objectivity and equanimity, by adequately ensuring the well-being and professional growth of their co-workers.

In turn, all employees must cooperate fully with their line managers, diligently complying with the work instructions given to them.

The Company is committed to protecting the environment as a primary asset.

To this end, it directs its choices in such a way as to ensure compatibility between economic initiatives and environmental requirements, taking into account the development of scientific research and the best experience in the field.

In accordance with the interest of the Company, each Recipient is directly and personally responsible for protecting and preserving its assets, both physical and intangible, and the resources, whether human, material or immaterial, entrusted to them to carry out their tasks, as well as the manner in which each use them.

None of the assets and resources owned by the Company shall be used for purposes other than those indicated by the Company.

Recipients must be aware of the existence of control procedures and aware of the contribution they make to achieving Company objectives and efficiency.

All operational levels are mutually responsible for creating an effective internal control system.

Consequently, all employees, within the scope of the tasks performed, are responsible for identifying, implementing and properly operating the controls over the operational areas entrusted to them.

Adequate, clear and complete documentation must support every action or transaction, of whatever type, carried out by the Recipients. Such documentation must be kept on file so that the reasons, characteristics and the persons who, in the various phases, authorized the transaction can be easily verified.

The information contained in periodic and/or accounting reports, both general and analytical, must comply with the principles of transparency, precision, completeness and accuracy.

Recipients who become aware of omissions, falsifications, alterations or negligence with the information and supporting documentation are required to report them to their line manager, if an employee, or to the internal contact, if a third party.

The Company and its employees shall verify in advance the information available (including financial information) on business associates, vendors, partners and consultants, in order to confirm their reputability and the legitimacy of their business before establishing business relations with them.

The Company refuses to enter into business relations with persons of unproven or dubious moral integrity.

The Company recognizes that free competition in a market economy is a decisive factor for growth and constant business improvement.

The Recipients undertake not to engage in acts that conflict with fair, loyal and transparent competition between companies.

Recipients must avoid any situation and refrain from carrying out any task that conflicts with the interests of the Company or is incompatible with the obligations undertaken towards the latter.

The occurrence of situations of conflict of interest is to be considered against the law and against the principles set out in the Code of Ethics.

Such situations, moreover, undermine the relationship of mutual trust between the Recipients and the Company and are detrimental to its image and protection.

Accordingly, anyone who is aware of situations of conflict of interest must promptly inform their line manager or those who are responsible for monitoring compliance with the Code of Ethics and the Model.

In accordance with the law, the Company guarantees the confidentiality of the information in its possession.

Company employees are prohibited from using confidential information for purposes unrelated to the performance of their job.


Contractual relations and communications with the Company's customers are based on the principles of fairness and honesty, professionalism, transparency and on the utmost collaboration.

Having direct or indirect relations with persons linked to criminal organizations or otherwise operating beyond the boundaries of the law is forbidden. Any irregularities should be promptly reported to the office managers.

The Company considers it essential to maintain the high quality standards of its services and to maximize customer satisfaction.

The internal procedures and technologies used support these aims, also by continuously monitoring customers.

Any complaints will managed as quickly and thoroughly as possible.

Suppliers shall be selected and purchasing conditions shall be established based on objective and transparent evaluations that take into account, among other things, the price, the ability to provide and guarantee services of an adequate level, as well as the honesty and integrity of the supplier.

Recipients may not accept gifts, gratuities and the like, unless directly owing to normal courtesy and provided they are of modest value.

If a Recipient receives proposals of fringe benefits from a supplier, they must immediately report this to their line manager.

Staff are hired under standard employment agreements, as no form of irregular work or exploitation is tolerated.

The methods of access to employment in the Company are based on the criteria of the transparency of its procedures. These methods shall be adequate to guarantee and verify full compliance with the principles and general rules of this Code of Ethics throughout the application stage and to provide adequate proof of the criteria and methods adopted when selecting the human resources to be hired.

When hired and during the course of their employment, staff shall receive clear and specific information on regulatory and remuneration aspects.

For the duration of their employment, they receive directions that enable them to understand the nature of their job and to carry it out accurately, in accordance with their qualifications.

The Company undertakes to promote and spread the culture of safety, developing awareness of risk management, promoting responsible behavior and preserving, especially through preventive actions, the health and safety of all employees and independent contractors.

All employees and independent contractors are required to scrupulously comply with the rules and obligations deriving from the relevant legislation on health, safety and the environment, as well as to comply with all measures required by internal procedures and regulations.

Employees and independent contractors, within the scope of their duties, shall participate in the process of risk prevention, environmental protection and health and safety protection for themselves, their colleagues and third parties.

The assumption of commitments with the Governmental Authority and with Government Agencies, national or international, as well as with private counterparties that are public service concession operators, is reserved exclusively to the authorized Company departments in charge.

The principles of honesty, transparency, collaboration and non-interference, as well as respect for each other's positions, shall be the basis for all potential relations between the Company and the abovementioned entities.

The Company rejects any conduct that may even be interpreted as collusive or otherwise liable to undermine the above principles.

In this context, no actions must be taken (directly or indirectly) - such as, for example, proposing employment and/or commercial opportunities that may benefit government representatives, soliciting or obtaining confidential information - that may compromise the integrity or reputation of both parties.

The Company prohibits all those who operate in its interest from accepting, offering or promising, even indirectly, money, gifts, goods, services, performances or favors not due to Civil Servants, executives, officers and employees in general of the Governmental Authority and Government Agencies or to their relatives and kin, to promote or favor the interests of the Company.

Offering gifts or benefits of modest value in countries where it is customary to offer gifts to customers in compliance with applicable laws and regulations is allowed, on the understanding that seeking favors for the benefit of the Company is prohibited.

During the audits and inspections by the competent Governmental Authority, the Recipients of this Code of Ethics must maintain an attitude of maximum availability and cooperation towards the inspection and control bodies.

Transparent and responsible conduct is also required when preparing the periodic reports and all other communications to be sent to the same authorities in accordance with the law and regulations.

Therefore, it is forbidden to conceal information or provide false or untrue documentation to these bodies, to prevent or in any way obstruct the functions of the Governmental Supervisory Authorities that come into contact with the Company by virtue of their institutional functions.

The Company does not make contributions to political parties, committees and political and trade union organizations.

When a contribution is considered appropriate for the public interest, that contribution must, however, be made in strict compliance with the laws in force and adequately recorded.

The Recipients must acknowledge that any form of involvement in political activities takes place on a personal basis, on their own time, at their own expense and in accordance with applicable laws.

Any relations between the Company and mass media are the responsibility of the specifically designated corporate offices and must be conducted in accordance with the communication policy established by the Company itself.

Participation, in the name of the Company or on its behalf, in committees and associations of any kind, whether scientific, cultural or professional, must be duly authorized and formalized in writing, in accordance with procedures.

The information and communications provided shall be truthful, complete, accurate, transparent and consistent with each other.


Violation of the provisions of this Code of Ethics impairs the relationship of trust established with the Company and may lead to disciplinary and/or judicial, civil or criminal action.

The Company will, therefore, unsparingly prosecute such violations by promptly and immediately imposing appropriate and proportionate disciplinary measures, regardless of the potential relevance of such conduct under criminal or civil law and instituting the relevant proceedings in the court having jurisdiction.

In cases judged to be more serious, the violation may lead to terminating the employment agreement, if carried out by the employee, or to interrupting the relationship, if carried out by a third party.

The penalties analytically provided for in the Organizational Model adopted by the Company under Legislative Decree No. 231 of 8 June 2001 shall apply to all Recipients.


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