Fondazione Ansaldo

English
Fondazione Ansaldo
 

Code of Ethics

Code of Ethics

 Ansaldo Foundation (Finmeccanica Group)

Approved by the Fondazione Ansaldo Executive Committee
 during the meeting held on 14 January 2015

CONTENTS

1. INTRODUCTION

2. GENERAL PRINCIPLES

3. HUMAN RESOURCES AND EMPLOYMENT POLICY

4. CONFLICTS OF INTEREST

5. OPERATING PROCEDURES AND ACCOUNTING DATA

6. PROTECTION OF THE FOUNDATION'S ASSETS

7. RELATIONS WITH THIRD PARTIES

8. DISCLOSURE

9. VIOLATIONS OF THE CODE OF ETHICS – SANCTIONS

1. INTRODUCTION

1.1 The Foundation

This Code (hereinafter referred to as the "Code of Ethics") lays down the commitments and ethical responsibilities in going about the business made by all those entertaining relations of any kind with “Fondazione Ansaldo (Gruppo Finmeccanica)” (hereinafter “(the) Foundation” or “Organisation”).

The principles and provisions of this Code of Ethics are binding on all the following parties:

-      The members of the Board of Directors in pursuing the Foundation's activities in all decisions adopted

-      The members of the Committees set up to support the Foundation's activities in performing those activities

-      The members of the Board of Auditors in auditing and verifying the formal and substantive correctness of the Foundation's work

-      All employees and all collaborators with whom contractual relations of any type exist, including occasional and/or purely temporary

-    All those entertaining financial or even free of charge relations of any kind with the Foundation

All Addressees undertake to pursue their objectives loyally, professionally, honestly, correctly, competently, transparently, diligently and in good faith, in complete compliance with all applicable laws and legislation.

1.2 Relations with Stakeholders

The cultural and social relevance of the Foundation's activities, the operations in the different contexts and the many parties it deals with makes management of relations between the Foundation and its stakeholders essential, with the latter term used to mean all public or private, Italian and foreign subjects - individuals, groups, businesses, institutions - by any way coming into contact with the Foundation and/or which in any case have an interest in the activities implemented by the same.

1.3 Principles of Reference

Compliance with the law, transparency and correct management, trust and cooperation with stakeholders; these are the general ethical principles that inspire the Foundation - and from which its models of conduct derive - in order to perform its activities with competence and intellectual and cultural rigour, manage its relationships with other cultural institutions, and develop the skills and favour the professional growth of its human resources. More specifically, the firm belief of acting in any way to the benefit of the Foundation does not justify the adoption of conduct in contrast with said principles. All Addressees, with no distinctions drawn or exceptions made, are therefore bound to comply with and ensure compliance with these principles as part of their duties and responsibilities. This commitment also requires subjects with which the Foundation entertains relations by any title to act in its regard with rules and methods that are inspired by these same values.

1.4 The Code of Ethics

The Foundation, like all legal bodies which belong or in any case refer to the Finmeccanica Group, has considered it appropriate and necessary to adopt and release a Code of Ethics that lays down the values that must be adopted by all Addressees, who must accept the relevant responsibilities, structures, roles and rules, violation of which, even if not resulting in any corporate liability with regards to third parties, shall be their personal responsibility both with regards to the Foundation itself and externally.  Knowledge of and compliance with the Code of Ethics by all those working for the Foundation are therefore primary conditions for the transparency and reputation of the Foundation.  The Foundation is also committed to spreading awareness of the Code of Ethics amongst all those with which it entertains relations, demanding that they be aware of it and respect the rules set out therein.

The Code of Ethics is also a preventive and reference instrument for ethical conduct in the Foundation's activities. The responsibility for the implementation and updating of the Code of Ethics and its application lies with the directors; the addressees are required to communicate any failure to comply with or apply the code to the General Manager of the Foundation and to the President of the Board of Auditors.

2. GENERAL PRINCIPLES

2.1 Compliance with laws and regulations

The Foundation operates in complete compliance with all applicable laws and legislation, in compliance with the principles established in the Code of Ethics.

Moral integrity is a constant duty of all Addressees.

Addressees are therefore required, each under the scope of their respective competences, to be aware of and observe all applicable laws and regulations.

The relations of the Addressees with the Authorities and Public Institutions must ensure complete correctness, transparency and collaboration, in full compliance with laws and legislation and their institutional functions.

2.2 Models and rules of conduct

All activities implemented by the Addressees must be carried out with professional commitment, moral rigour and managerial correctness, also with a view to protecting the Foundation's image.

The conduct and relations of all Addressees, within and outside the Foundation, must be inspired by transparency, correctness and mutual respect. In this context, the directors must first provide an example in their work for all the Foundation's human resources, in going about their duties keeping strictly to the principles behind the Code of Ethics, ensuring their dissemination amongst employees and asking that they submit requests for clarification and/or proposals for updates wherever necessary.

With specific reference to the Directors, moreover, the Foundation asks that they take action to propose and develop such projects, investments and initiatives as may be useful to preserving and increasing the economic and cultural assets of the Foundation. 

2.3 Dissemination of and compliance with the Code of Ethics

The Foundation promotes the awareness of and compliance with the Code of Ethics amongst all Addressees, demanding due compliance with such and, in the event of any non-compliance, providing for suitable disciplinary or contractual sanctions. The Addressees are therefore required to be aware of the contents of the Code of Ethics - requesting and receiving from the organisational units appointed to this end all appropriate clarifications of the interpretation of the content - to comply with them and help implement them, reporting any deficiencies and violations (or attempted violations) of which they may become aware. 

3. HUMAN RESOURCES AND EMPLOYMENT POLICY

3.1 The key conditions

Human resources are and essential element to the Foundation's existence and a critical factor in successfully carrying out its activities. Ethics, respect, merit, professionalism, innovation, excellence, internationalism, multiculturalism, rights and sustainability are therefore key conditions in achieving the Foundation's objectives and are the characteristics required by the Foundation of its directors, auditors, employees and other collaborators.

The Foundation shall act to eliminate any type of discrimination, corruption, exploitation of child labour or forced labour and, more generally, to promote dignity, health, freedom and equality of workers, in compliance with the Universal Declaration of the United Nations, the essential conventions of the International Labour Organisation (ILO) and the OECD Guidelines.

3.2. Selection Policies

In order to contribute towards the development of its objectives and ensure that said objectives are all pursued in compliance with the ethical principles and values inspiring the Foundation, the Foundation aims to select each employee and collaborator according to the above-mentioned values and characteristics. The Foundation therefore offers equal opportunities of work, guaranteeing fair treatment on the basis of individual skills and capacities. Under the scope of the selection - carried out in compliance with equal opportunities and with no discrimination of any type on the private sphere and opinions of candidates - the Foundation operates to ensure that the resources acquired meet with the professional profiles it actually requires, avoiding any favouritism and benefits of any type and basing the choice exclusively on criteria of professionalism and competence.

The foundation's staff and collaborators are hired on valid employment contracts, in compliance with applicable legislation and collective contracts. More specifically, the Foundation does not allow and does not tolerate any establishment of employment – including by external collaborators, suppliers or business partners – in violation of current legislation governing child labour, women's employment and immigration legislation.

3.3 The development of professionalism

In the evolution of the working relationship, the Foundation is committed to creating and maintaining the conditions necessary to ensure that the capacities and knowledge of each and every person may further extend in respect of said values, according to a policy based on the recognition of merits and equal opportunities. By virtue of this, employees are required to cultivate and actively acquire new skills, capacities and knowledge, whilst managers and directors of the organisational units must pay careful attention to optimising and increasing the professionalism of their employees and collaborators, creating the conditions for the development of their capacities and the realisation of their potential.

Staff selection and management must be inspired by principles of correctness and impartiality, avoiding favouritism and discrimination and respecting worker professionalism and skills.

In the pursuit of the Foundation objectives, the worker must in any case operate with the awareness that ethics are of primary interest to the Foundation and that, therefore, no conduct will be tolerated which, even if appearing to favour the Foundation, is in contrast with applicable legislation or this Code of Ethics.

3.4 Human resources and the Code of Ethics

The Foundation promotes and ensures knowledge of the Code of Ethics. The information and awareness of the Code of Ethics is ensured by its distribution to all employees and collaborators at the time the contract comes into force; these parties are then required to sign a declaration that they have read the Code of Ethics, along with a declaration guaranteeing a lack of conflict of interests.

3.5 The workplace and the protection of privacy

The Foundation undertakes to create a workplace that guarantees that all Addressees and, more specifically, all employees and collaborators of any type and level, can enjoy conditions that are respectful of their health, safety and personal dignity and in which the characteristics of individuals cannot give rise to discrimination or influence.

The Foundation, in compliance with applicable provisions, undertakes to protect worker health, taking all steps necessary and appropriate on the basis of the best technical and scientific knowledge, with a view to guaranteeing absolute conformity of the workplace with the highest health and safety standards. 

In complete compliance with the Italian Data Protection Code and legislation designed to protect the privacy of all Addressees and, more generally, all those in any way having contact with the Foundation, the latter also prohibits any undue disclosure and/or dissemination of personal data without the prior consent of the data subject.

More specifically, respect for the dignity of the worker must also be assured through respect for privacy in correspondence and interpersonal relations amongst employees through the prohibition to interfere in conferences or dialogues and the prohibition of an interference or forms of control that may damage personality.

The Foundation is committed to protecting the moral integrity of all employees and/or collaborators, guaranteeing them a right to working conditions that are respectful of personal dignity and complete exercise of trade union and political rights. The Foundation safeguards workers from acts of psychological violence or workplace harassment and fights any behaviour or conduct that is discriminatory or harmful to the person, their beliefs and inclinations. It is specifically prohibited to use any form of persecution in working relationships or, more generally, to act in any way that may compromise the peaceable performance of their assigned duties, or in any case that may harm the worker's dignity.

The Foundation also takes suitable measures and steps to guarantee the security, integrity, correct use and operation of the systems, programs, IT or electronic data of the Foundation and third parties, also protecting the intellectual property rights connected with the use of programs and IT and electronic data and, more generally, of intellectual works, and the integrity of information made available to the public through the internet.  

4. CONFLICTS OF INTEREST

4.1 Foundation and Individual Interests

There is complete trust between the Foundation and its directors and employees, under the scope of which the director and employee have the primary duty of using the Foundation's assets and their working skills in the Foundation's interests, in compliance with the principles established in the Code of Ethics.

In these terms, the directors, employees and those who collaborate with the Foundation in various ways must avoid all situations and abstain from any actions that may juxtapose a personal - direct or indirect - interest with those of the Foundation or which may interfere and hinder the capacity to impartially and objectively make decisions in the interests of the Organisation. The occurrence of situations of conflict of interest, in addition to being in contrast with the provisions of law and principles established in the Code of Ethics, is prejudicial to the Foundation's image and integrity.

Once they have signed the declaration of no conflict of interests at the time the contract comes into force – see point 4.2 below – Addressees must therefore exclude all possibilities of a juxtaposition, or in any case crossover of, using their position, the economic activities that meet with a logic of personal and/or family interests and the duties they carry out or offices held in the Organisation. Any situations of actual or potential conflict of interest that may arise after the start of the contract must be promptly reported in detail to the Foundation, represented by the President of the Board of Directors or the President of the Board of Auditors, as well as the General Manager. The party with a potential conflict of interest must abstain from carrying out or participating in acts that may damage the Organisation or third parties, or compromise its image.

Equally, consultants and partners must make specific commitments aimed at avoiding situations of conflict of interest, further abstaining from using the activities carried out on behalf of the Foundation, in any way and on any grounds, in order to obtain undue advantage for themselves or others

4.2 Prevention of Conflicts of Interest

In order to avoid any situation of actual or potential conflict of interest, when assigning an appointment or starting a contract of employment, the Foundation requires its directors, auditors, employees and external collaborators of all types to sign a specific declaration that no conditions exist which would represent a conflict of interest between an individual and the Organisation. This declaration also establishes that the subject shall undertake to promptly report details to the President of the Board of Directors and the President of the Board of Auditors, as well as the General Manager should they find themselves in a situation with a (potential) conflict of interests.

The Foundation also asks anyone with information of situations of conflict of interest to report this to the President of the Board of Directors and the President of the Board of Auditors, as well as the General Manager.

5. OPERATING PROCEDURES AND ACCOUNTING DATA

5.1 Transparency of the Accounts

Truthfulness, accuracy, completeness and clarity of the basic information are the essential conditions for enabling a transparent accounting entry and constitute a fundamental value for the Foundation, also with a view to guaranteeing partners and third parties the possibility of having a clear view of the Foundation's economic, equity and financial position.

For this value to be respected, it is first essential that the documentation of the basic elements in the accounts supporting the entries is complete, clear, truthful, accurate and valid, and is kept on file for all required checks. The connected accounting entries must provide a complete, clear, truthful, accurate and valid reflection of what is described in the supporting documentation. In the event of economic-equity elements based on evaluations, the related entry must be complete with respect to the criteria of due care, reasonableness and congruousness, clearly illustrating the criteria that guided the determination of the value of the asset in the relevant documentation.

Anyone becoming aware of any possible omissions, falsifications or irregularities in the book-keeping and supporting documentation or in any event a violation of the principles established by the Code of Ethics, must report this promptly to the the President of the Board of Directors and the President of the Board of Auditors, as well as the General Manager. Such violations affect the trust afforded with the Foundation and are significant in disciplinary terms and shall therefore by suitably sanctioned.

Within the limits established by current legislation, the Foundation shall promptly provide complete information, clarification, data and documentation as required by the founding members, supporters, suppliers, supervisory authorities, institutions or other bodies in going about their respective activities and functions. All relevant information must be communicated promptly to both the Board of Auditors and the competent authorities.

6. PROTECTION OF THE FOUNDATION'S ASSETS

6.1 Custody and Management of Resources

The Foundation shall act to ensure that the use of the available resources - in compliance with applicable legislation and the contents of the charter, and in line with the values of the Code of Ethics - aims to guarantee, increase and strengthen its equity, protecting the Foundation, its founding members and supporters, creditors and stakeholders in general. For this reason, Foundation assets must be used exclusively in the interests of the Foundation and in compliance with the law and applicable legislation.

7. RELATIONS WITH THIRD PARTIES

7.1 Relations with public institutions and authorities and other parties representing collective interests

7.1.1 Relations with the Public Administration and Authorities

Relations regarding the Foundation's Activities with public officials or other parties assigned to public service - working on behalf of the Public Administration, Central or Peripheral, or legislative bodies, EU institutions, international public organisations and any foreign state - with the judiciary, public supervisory bodies and other independent authorities, as well as with private partners who are operators of a public service, must be undertaken and managed in a spirit of collaboration, fully respecting all applicable laws and regulations and the principles laid out in this Code of Ethics, in such a way as not to compromise the integrity and reputation of either party.

As regards its relations with Italian and foreign institutions, the Foundation commits to represent its own interests and put forward its own requirements in an appropriate and transparent manner, fully respecting the principles of independence and impartiality as regards the choices of the public administration and in such a way as not to lead it into errors or influence its decisions. In order to ensure maximum clarity in such relationships, contact with international bodies is performed exclusively by authorised parties and in such a way as to guarantee the correctness and traceability of such contact.

7.1.2 Relationships with Political and Labour Organisations

The foundation does not favour or discriminate against, either directly or indirectly, any political or trade union organisation.

The foundation does not provide any form of support or contribution, either direct or indirect, to trade union or political parties, movements, committees and organisations, their representatives and candidates, except for those required by specific legal provisions.

Addressees who perform activities of a political or trade union nature for any reason shall not involve the foundation in any manner or any form, directly or indirectly, or use the Foundation's tangible and intangible assets and materials (such as its name, brand, headquarters, equipment and tools, archival heritage, communications channels and websites) in performing such activities. Violation of this prohibition shall represent a breach of trust between the Foundation and the Addressee in question, and shall be sanctioned according to the provisions of this Code.

7.1.3 Gifts, presents, Benefits and Promises of Favours

The Foundation prohibits Addressees from making or accepting undue promises or gifts, benefits (direct and indirect), presents, acts of courtesy and hospitality in relation to relationships with public officials, operators of public services or private citizens in order to influence decisions due to favourable treatment, undue service or any other end.

In its relations with Italian and foreign public administration officials, the Foundation commits not to improperly influence their activities, choices or decisions through, for example, offers of undue advantages such as sums of money or other, the opportunity to use or assignment of consultancy services to their family members or any person or body connected to them. Any requests for offers of money or favours of any type (including but not limited to gifts of more than nominal value) made to or by those working on behalf of the Foundation in the context of relations with Italian or foreign public administration bodies all private parties must be brought immediately to the attention of the President of the Board of Directors and the President of the Board of Auditors, as well as the General Manager, who shall put into action the consequence of administrative procedures.

As regards any requests of any nature from the judicial authorities, and more generally any contact with such authorities, the Foundation pledges to offer its utmost collaboration and to abstain from conduct which might represent an obstruction or prejudice to such requests, in full compliance with applicable laws and regulations and in conformity with the principles of fairness, accuracy and transparency.

7.2 Relations with Consultants, Suppliers and Business Counterparties

7.2.1 Conduct in Business

In its activities, the Foundation is inspired by principles of fairness, correctness, transparency, efficiency, respect for the law and values laid down in the Code of Ethics, and demands the same conduct from of all those with which it entertains relations of any kind, to this end paying careful attention in choosing its business counterparties, suppliers, business partners, consultants, etc.

The Foundation shall not entertain relations of any kind, even if indirect or through a third party, with parties (natural persons or legal entities) that are known or suspected of being part of or carrying out in Italy or abroad any activities in support, in any way, of criminal organisations of all types, including Mafia type organisations, those involved in human trafficking and child labour or weapons trafficking and subjects or groups operating with terrorist aims, considered as conduct that may seriously damage a country or international organisation, carried out with a view to intimidating the population or forcing the public powers or an international organisation to act or avoid acting in a certain way or destabilising or destroying the fundamental, constitutional, economic and social political structures of a country or international organisation.

Special attention must also be paid to relations involving the receipt or transfer of sums of money or other gains. Specifically, in order to prevent the risk of carrying out, even if involuntary or unknowingly, operations of any type concerning money, goods or other utilities that are the proceeds of crime, the Foundation shall abstain from receiving any payments in cash, bearer bonds or through unqualified intermediaries or the involvement of third parties, in such a way as to make it impossible to identify the party disbursing the amount or from having relations with subjects based or in any case operating in countries that do not guarantee corporate transparency and, more generally, from carrying out operations such as to prevent the reconstruction of the financial flow.

In its relationships with third parties, the Foundation also avoids conduct which could in any way compromise the integrity, reliability and security of IT or electronic data and systems.

The selection of business counterparties, business partners, consultants and suppliers of goods, merchandise and services must take place on the basis of objective, transparent and documented evaluation criteria, in compliance with the principles of this Code of Ethics, with any business negotiation involving sums of over EUR 5,000 (five thousand Euros) required to be put in writing. In any case, the selection must be made exclusively on the basis of objective parameters such as quality, value for money, price, professionalism, competence, efficiency and where suitable guarantees are given with regards to the correctness of the supplier, provider or consultant. More specifically, the Foundation undertakes not to establish any relations with any parties known or suspected of using child labour or staff not regularly employed or which in any case operate in breach of laws and legislation on the protection of worker rights. Special attention must be paid to relations with subjects operating in countries in which there is no legislation offering sufficient worker protection in terms of child labour, women's employment and immigration, ensuring the sufficient health, hygiene and safety conditions are assured.

In transactions of any nature, care must be taken in receiving and disbursing sums of money, goods or other benefits, and in checking that provisions disbursed and received are correct and complete. It is, in any case, prohibited to make any payments in cash.

Collaborators, consultants and/or intermediaries are required to report back regularly to the Foundation on the activities carried out.

The Foundation reserves the right to carry out audits, including through third parties contracted for the purpose, in order to verify compliance with contractual obligations.

7.2.2 Gifts, Benefits and Payments

The Foundation prohibits the accepting, offering or promising, directly or indirectly, of any payments, benefits (whether direct or indirect), gifts, favours or hospitality in connection with relations entertained with consultants, suppliers, business partners etc. in order to obtain more favourable treatment, except those of nominal value which do not put the Organisation's image at risk.

Directors, auditors, committee members, employees or collaborators receiving gifts representing more than a normal act of courtesy of nominal value, in order to obtain favourable treatment in relation to any activity relating to the Organisation, must immediately notify the Board of Directors, the President of the Commission all the Board of Auditors, respectively, or the General Manager of the Foundation for employees and collaborators.

7.3 Environmental Protection

The Foundation recognises the environment as a primary good to be safeguarded and to this end limits the environmental impact of its activities, also considering the development of scientific research in the area.

8. DISCLOSURE

8.1 Availability of and Access to Information

Within the limits established by current legislation, the Foundation shall promptly provide complete information, clarification, data and documentation as requested by partners, suppliers, supervisory authorities, institutions or other bodies in going about their respective activities and functions. 

8.2 Relations with the Mass Media and Management of Information

Relations with the press and other communication and information media are marked by respect for the right to information and protection of the market and the interests of the stakeholders.

The dissemination of information relating to the Foundation is exclusively the responsibility of those specifically assigned to these duties by the Board of Directors. Any request for information by the press or other media received by Foundation staff must be communicated to the General Manager of the Foundation prior to making any commitment to fulfil the request.

External communication must apply the guiding principles of truthfulness, correctness, transparency and suitability, and must aim to ensure knowledge of the Foundation's activities, initiatives programmes and projects. Relations with the mass media must be compliant with the law and the Code of Ethics, the related protocols and principles already outlined with reference to relations with public institutions and with the aim of protecting the Foundation's image.

9.    VIOLATIONS OF THE CODE OF ETHICS – SANCTIONS

9.1 Reporting of Violations

The Organisation shall guarantee that no one in the workplace suffers retaliation, unlawful influence, ill-ease or discrimination of any type for having reported to the Supervisory Body the violation or attempted violation of of the provisions of its Code of Ethics.

Following a report, the Foundation shall promptly carry out all appropriate checks and apply suitable sanctions.

9.2 Sanction System

9.2.1 General Principles

Violation of the principles established in the Code of Ethics compromises the trust enjoyed between the Foundation and the Addressees.

Such violations shall therefore be actively pursued by the Foundation in a prompt, immediate fashion, with suitable, proportional disciplinary proceedings, regardless of any criminal relevance of said conduct and the initiation of criminal proceedings should the violation constitute a crime.

The effects of the violation of the principles laid down in the Code of Ethics must be considered seriously by all Addressees: to this end, the Foundation shall distribute the Code of Ethics and provide information on the sanctions envisaged in the event of violation and on the methods and procedures for their application, including via its website, www.fondazioneansaldo.it.

To protect its image and safeguard its resources, the Foundation shall not entertain any relations with any parties not intending to operate in complete compliance with applicable legislation and/or which refuse to behave in accordance with the values and principles set forth in the Code of Ethics.

9.2.2 Directors, Auditors and Committee Members

In the event of violation of the Code of Ethics by one or more Directors and/or Auditors and/or Committee Members, the General Manager of the Foundation shall inform the Board of Directors and the Board of Auditors which, according to their respective responsibilities, shall adopt one of the following initiatives, considering the seriousness of the violation and in compliance with the powers provided for in law and/or the Charter:

-        Declarations in the minutes of the meetings

-        Formal warning

-        Revocation of the appointment/delegation

-        Request for the for the competent bodies to adopt suitable provisions with regards to the parties responsible for the violation; such measures may include legal action to ascertain the liability of the individual towards the Foundation and ensure all damages suffered are remedied

In particular, as concerns the Foundation's Directors, considering that these are nominated directly by the founding members or co-opted by the Board of Directors, in the event that violations of the Code of Ethics should come to light such as to compromise the relationship of trust or there should otherwise exist serious reasons connected to the protection of the Foundation's interest and/or image, the Board of Directors shall be convened to decide on the following: (i) Revocation of the mandates when the Director in question has been cooperated by the Board, or (ii) Formal notification of the supporter who made the nomination in order that the appropriate measures can be taken, when the Director has been nominated directly by a supporting member.

9.2.3 Employee Sanctions

Managers

In the event of any violation by managers of the principles and provisions of the Code of Ethics or the adoption, in going about their duties, of any conduct not compliant with its provisions, the most appropriate measures shall be applied to those responsible, in compliance with the provisions of the applicable collective employment contract. Specifically:

-        Where the violation of one or more of the provisions of the Code of Ethics is of such severity as to damage the trust enjoyed and prevent the full or temporary continuation of the employment relationship, the manager shall incur the provision of TERMINATION OF EMPLOYMENT WITHOUT NOTICE

-        If the violation is minor, but still sufficiently severe as to irreparably damage the trust afforded, the manager shall incur the provision of JUSTIFIED TERMINATION OF EMPLOYMENT WITH NOTICE

Employees and Middle Management

Any conduct of employees in violation of the individual rules of conduct established by this Code of Ethics is defined as a “disciplinary violation”.

In relation to the above, the Code of Ethics makes reference to the disciplinary structure covered by the applicable collective contract.

The abstract categories of violations describe the sanctioned conduct, identifying the related disciplinary provisions according to their seriousness. Specifically:

A) The sanctions of VERBAL WARNING, WRITTEN WARNING, FINE OR SUSPENSION FROM WORK AND SALARY, according to the severity of the violation, shall be incurred by any worker violating internal procedures as laid down by the Code of Ethics or adopting, in going about their activities in the related risk areas, conduct that is not compliant with the provisions of the Code, with such violations including those of the duties of the employee as identified by the collective contract of employment, prejudicial to the discipline and morale of the Organisation

B) The sanction of TERMINATION OF EMPLOYMENT WITH NOTICE shall be incurred by any worker, in going about their activities in the risk areas, committing a significant breach of the provisions of the Code of Ethics, with such violations consisting of those more severe than those identified under point A above

C)The sanction of TERMINATION OF EMPLOYMENT WITHOUT NOTICE shall be incurred by any worker, in going about their activities in the risk areas, acting in a clear, direct manner aimed at committing a crime in violation of the provisions of the Code of Ethics, with such conduct consisting of a very severe violation causing the Foundation severe moral and/or material harm

9.2.4  Collaborators, Consultants, Partners, Counterparties and other Third Parties

All conduct implemented under the scope of a contractual relationship by collaborators, auditors, consultants, partners, counterparties or other parties external to the Foundation, in contrast with the lines of conduct indicated by this Code may determine termination of the relevant contract through corresponding clauses which the Foundation includes in all contracts.




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