Code of Ethics

V.i.p. Italia S.r.l. (hereinafter Vip) aims to work in compliance with the principles of loyalty, legality and fairness, principles on which the success and growth of the company are based.
In pursuing this objective, in June 2016, the Code of Ethics on which Vip bases its work was approved.
The Code wants to be the address of the company’s behavior, whose observance is essential and of primary importance for the proper functioning, reliability, reputation, image of the company and customer satisfaction. These factors constitute the foundations for the current and future development of the company and the companies represented for the prevention of crime. The commitments described in the Code are addressed to all those who interact with Vip: customers, collaborators, consultants, suppliers, competitors and shareholders, all in equal measure called to protect and respect the image and integrity of the company.

Principles of conduct for the organization

The principles listed below are considered fundamental, so Vip is committed to respecting them towards everyone. On the other hand, Vip claims that these principles are respected by all subjects, internal and external, who maintain relations of any nature with the same.

Compliance with laws and regulations

Vip operates in accordance with the law and strives to ensure that all personnel act in this sense: people must behave in accordance with the law, whatever the context and activities carried out. This commitment must also apply to consultants, suppliers, customers and anyone who has relations with the company.

Integrity of behaviour

Vip is committed to providing quality services and to competing on the market according to principles of fair and free competition and transparency, maintaining fair relations with public, governmental and administrative institutions, citizens and third-party companies.

Discrimination

In decisions affecting relationships with its stakeholders (customer choice, relationships with capital owners, personnel management and work organisation, selection and management of suppliers, relationships with the surrounding community and the institutions representing it), Vip avoids any discrimination on the basis of age, sex, sexuality, state of health, race, nationality, political opinions and religious beliefs of its interlocutors. The same criterion is also applied in relations with staff as well as in the selection and recruitment phases.

Development of human resources

Vip acknowledges that human resources are a key factor in its development, ensuring a safe working environment that facilitates the performance of work and enhances the professional skills of each. The working environment, inspired by respect, fairness and collaboration, must allow the involvement and accountability of people, with regard to the specific objectives to be achieved and the ways to pursue them. The management of human resources is based on respect for the personality and professionalism of each person, guaranteeing their dignity and respect. Vip refuses any form of forced labor, or performed by people of the minimum age allowed to carry out the activity, and does not tolerate human rights violations.

Fairness of authority

In hierarchical relationships, Vip is committed to ensuring that all forms of abuse are avoided. Vip will prevent abuse of a dominant position. In any case, the above values must also be safeguarded in the choice of work organisation.

Health, safety and environmental protection

Vip intends to conduct its business in a correct way from the environmental point of view. It also takes care to disseminate correct and truthful information about its activities.

Prohibition of unethical behaviour

It is not considered ethical and promotes the assumption of hostile attitudes towards Vip behavior of anyone, individual or organization, trying to appropriate the benefits of the collaboration of others, exploiting positions of strength.

Correctness in contractual matters

Contracts and assignments must be carried out according to what is consciously established by the parties: Vip undertakes not to exploit conditions of ignorance or incapacity of its counterparts. It must also be avoided that, in existing relationships, anyone who operates in the name and on behalf of Vips and tries to take advantage of contractual gaps or unforeseen events to renegotiate the contract, for the sole purpose of exploiting the position of dependence or weakness in which the interlocutor has found himself.

Protection of competition

Vip intends to protect the value of fair competition by refraining from collusive, predatory and abuse of position. Therefore, all entities that in various ways work with Vips will not be able to participate in agreements that conflict with the rules governing free competition between companies.

Enhancement of the Company’s investment

Vip strives to ensure that the results, including economic/financial, are such as to enhance the investment of the capital owner.

Transparency and completeness of information

Vip is required to provide complete, transparent, understandable and accurate information, so that, in setting up the relationship with the company, stakeholders are able to make independent decisions and aware of the interests involved, the relevant alternatives and consequences. In particular, in the formulation of any contracts, Vip must take care to specify the relevant clauses in a clear and understandable.

Protection of personal data

Vip collects and processes personal data of customers, capital owners, collaborators, employees and other subjects, both physical and legal persons, as well as sensitive data such as health status or union choices. Vip undertakes to process such data within the limits and in accordance with the provisions of current legislation on privacy, with specific reference to Legislative Decree 196/2003 (“Privacy Code”) and related annexes, as well as the requirements of the Data Protection Supervisor. The Vip staff that is, in the field of work, to process sensitive data and not, must always proceed in compliance with the aforementioned legislation and the operational instructions given.

Control of work activity

Vip can adopt procedures of control and verification of work activities, for security or organization reasons. These controls, both purely “defensive” and organizational, must comply with the relevant legislative provisions and must not exceed limits of reasonableness, in relation to the results to which they tend.

Information processing

The information about the counterparties is processed by Vip in compliance with the confidentiality of the data subjects.

Principles of conduct to be followed by staff

People (administrators, employees and collaborators) dealing with Vip must adhere to the following principles:

Professionalism

Each person carries out his work and his performance with diligence, efficiency and fairness, making the most of the tools and time available and assuming the responsibilities related to the fulfillment.

Loyalty and honesty

People must be loyal to society. As part of their work, people are required to know and diligently comply with the organisational model and laws in force. In no case can the pursuit of the interest of Vip justify conduct that is not honest or does not comply with regulations.

Correctness

Persons shall not use for personal purposes – except to the extent permitted – information, goods and equipment, which they possess in the performance of the function or tasks assigned to them. Each person does not accept or make, for himself or for others, any pressures, recommendations or warnings, which may prejudice Vips or undue advantages for themselves, Vips or third parties; each person refuses and does not make promises of undue offers of money or other benefits.

Confidentiality

Persons shall ensure the utmost confidentiality with regard to news and information constituting the corporate assets or relating to the activities of companies belonging to Vip, in compliance with the provisions of law, current regulations and internal procedures. In addition, individuals are required not to use confidential information for purposes unrelated to the exercise of their business.

Conflicts of interest

Persons shall promptly inform their superiors or contact persons of situations or activities in which there may be a conflict of interest with that of Vip, direct or indirect, and in any other case where there are relevant reasons of convenience. People respect the decisions made by Vip.