| Release date | Version | Description | Author | Reviewer | Approver |
|---|---|---|---|---|---|
| 1/10/2024 | 1.1 | First release | Colin & Partners | Board of Directors | |
The Company GATE REAL ESTATE INNOVATION SRL SOCIETÀ BENEFIT (hereinafter also the “Company” or “GATE REI”) recognizes the importance of ethical and social values in carrying out its activities, in pursuing its objectives and, in general, in activities functional to pursuing its business goals. In this regard, it is committed to responsible and prudent management of its own activities and of the stakeholders with whom it interacts.
This Code of Ethics (hereinafter also the “Code”) is aimed in this direction and has the following purposes:
The Company considers the following behaviors unethical:
The rules of conduct, values and principles to which the Company is inspired are part of its governance system, establishing GATE REI’s commitment to limit its freedom to operate in merely opportunistic terms and to ensure all stakeholders forms of participation and dialogue. The governance system ensures efficient and effective management of the Company’s activities, as well as the establishment of a system of controls over operational risks.
The Company acts to have these codified principles shared and adopted by management, shareholders, employees and collaborators, suppliers and customers.
This Code of Ethics consists of:
In order to ensure that the activities of its services are carried out in compliance with the law, integrity and fairness, with honesty and good faith, the Company will ensure wide dissemination of this Code.
This Code of Ethics is resolved by the Board of Directors and conforms to the contents of the “Guidelines for the construction of organization, management and control models pursuant to Legislative Decree of 8 June 2001, no. 231”.
Ethics in business activity is a fundamentally important element for the success and credibility of a company. Adherence to ethical principles makes it possible to obtain greater competitive advantage and better socio-economic development.
This Code governs conduct relevant from an ethical standpoint in order to enable knowledge and appreciation of the values it embodies.
The Recipients of the Code of Ethics (hereinafter also the “Recipients”) are:
All Recipients are required to observe and, within the scope of their responsibilities, ensure compliance with the principles contained in the Code of Ethics.
The intention to act in the interest of GATE REI does not justify conduct that conflicts with generally understood rules.
The Company has identified a specific “Supervisory Body” (hereinafter also the “OdV”) with the task, among others, of monitoring the application of and compliance with the Code of Ethics, also providing for sanctions in the event of violations.
The rules contained in this Code of Ethics supplement the behavior that Recipients are required to observe by virtue of civil and criminal laws in force in all the countries in which GATE REI operates.
Recipients of the Code of Ethics who violate its rules damage the relationship of trust with the Company and will be subject to the penalties provided.
Application of the Code of Ethics is entrusted to the Supervisory Body.
Revision of the Code is approved by GATE REI’s Board of Directors, upon proposal of the Chief Executive Officer in agreement with the Chair, after hearing the opinion of the Board of Statutory Auditors.
The proposal is formulated taking into account the evaluation of Stakeholders with reference to the principles and contents of the Code, also by promoting their active contribution and reporting of any shortcomings.
Each Company Representative, in carrying out their duties, must respect the principles of fairness, good faith, transparency, loyalty and integrity, towards both colleagues and third parties with whom they interact.
The principle of transparency is based on the truthfulness, clarity and completeness of information, meaning that those responsible for providing any information must provide clear and truthful information, adopting verbal or written communication that is accessible and immediately understandable.
The principle of fairness implies respect for the rights of others, understood not only as adherence to the rules in force but as respect for rights in the broadest possible sense, avoiding undue violations of privacy, discrimination against personnel, conflicts of interest and anything else that may be discriminatory or harassing within work and professional activity.
The principle of efficiency involves all the workforce, which must be committed to delivering the maximum result with all possible effort. In performance and service delivery, there must always be a commitment to offer a service suited to customer needs and to the most advanced standards of each sector and area of activity, in light of the optimal use of technological resources.
The service spirit is nothing more than full adherence to the corporate mission, recognized in an individual and collective effort aimed at achieving the best performance in terms of reliability, concreteness, versatility, agility and passion as well as output and productivity.
The professional development of human resources is the fundamental factor for the growth and development of business activity. Promoting professional growth increases the skills that form part of the Company’s assets.
Behavior among personnel, at all levels and degrees of responsibility, is constantly aimed at facilitating the best possible performance in a collaborative and synergistic spirit.
GATE REI encourages mutual collaboration and team spirit with respect for each person’s moral character and firmly condemns any prejudice, discrimination, unlawful conditioning or undue advantages.
GATE REI shares the value of fair competition, fairness and loyal competition with respect to all its competitors. All GATE REI staff, each according to their duties and responsibilities, must refrain from engaging in behavior that conflicts with EU or national provisions protecting free competition.
It is forbidden to use unlawful means to acquire trade secrets or other confidential information of competitors, to engage in illegal practices such as industrial espionage, or to hire employees of competing companies for the purpose of obtaining confidential information or solely to harm competitors.
Prevention of corruption and money laundering
Recipients who represent the Company or act in its interest, or have business relations with it, must refrain from any form of corruption, whether public or private. Therefore, no form of payment or granting of advantages is permitted to customers, counterparties and third parties in general that is not strictly derived from a contractual obligation. Company employees may accept or offer gifts provided that they are directly related to the activity carried out, lawful, of modest value, offered transparently and explicitly, occasional or given on customary gift-giving occasions, and that they do not create any obligation or perception of obligation on either side. All financial transactions have adequate justification in the existing contractual relationships and are carried out in a traceable manner. The Company rejects any conduct aimed at using, substituting, transferring or concealing sums of money of dubious illicit origin.
Human resources are the central element on which the Company bases the pursuit of its objectives. In the selection and management of personnel, the Company adopts criteria of merit, competence and assessment of individual abilities and potential. The Company values and strives to develop the skills and abilities of each Recipient, including through the organization of training and professional development activities. Each Recipient diligently undertakes such activities and reports any needs for further or specific activities in order to allow the Company to adopt the necessary initiatives. GATE REI recognizes and respects the role of trade unions and their full right to exercise their activities of representing workers and promotes the dissemination of a proper system of industrial relations, also through strengthening the participation of workers and unions in the Company’s development. It is the Company’s objective to consolidate a working environment characterized by the absence of racial, cultural, ideological, sexual, physical, moral, religious or other discrimination and to offer Recipients equal opportunities under equal conditions. All Recipients are required to cooperate in achieving this goal. Recipients cooperate with each other in achieving common results and are committed to creating a calm, stimulating and rewarding working environment. Within the workplace, Recipients maintain conduct marked by seriousness, order and decorum. The Company requires that no incidents of harassment or intolerance occur in internal working relationships.
In pursuing its corporate purpose, GATE REI interacts with employees, customers, suppliers, associations, authorities, shareholders and citizens (“stakeholders”). In relations with these parties, GATE REI is inspired by the principles of legality, fairness, transparency, impartiality and independence.
All stakeholders are recipients of this Code of Ethics and are required to comply with laws, regulations and company procedures. They must also maintain proper conduct so as not to undermine their moral and professional reliability.
The dissemination of misleading and detrimental information is avoided and no one may use their position within the Company to carry out other activities that are in conflict or competition with corporate activities.
These rules are designed to safeguard the principles of integrity and transparency in compliance with current regulations and company practices.
Attitudes and actions aimed at soliciting personal advantages for oneself or others, improperly influencing the counterparty’s decisions or requesting unjustified preferential treatment in relations with third parties, the public administration and political or trade union organizations are prohibited.
GATE REI undertakes to satisfy its customers in compliance with the obligations established by current regulations, the contracts entered into and the predetermined quality standards.
Work activity is oriented towards customer satisfaction and protection, paying particular attention to specific requests and favoring solutions oriented to product quality and the interpretation of customer needs, proposing, where appropriate, suitable decision-making processes and business perspectives.
GATE REI offers the customer a project and contractual approach inspired by a logic of true partnership, aiming for cutting-edge solutions that create value, endure over time and are easy to use.
For this reason, GATE REI directs its research, development and marketing activities towards high quality standards for its products and services.
GATE REI also undertakes to listen to any suggestions and to respond to complaints, always with the aim of ensuring the highest quality standard.
The selection of suppliers and the determination of purchasing conditions are based on an objective assessment of quality, the price of the requested goods and services, and the ability to supply and ensure goods and services in a timely manner at a level appropriate to the Company’s needs.
GATE REI adopts supplier selection criteria based on compliance with current regulations and internal rules; under no circumstances should a supplier be preferred over another because of personal relationships, favoritism or advantages other than those of the exclusive interest and benefit of GATE REI.
Human resources are the fulcrum around which the essence of GATE REI revolves.
For this reason, GATE REI protects and promotes the value of human resources, considering them indispensable for its existence, development and success, with the aim of improving and increasing its assets and the Company’s competitiveness, which grow in step with the development of the skills possessed by each collaborator within the organizational context.
GATE REI offers equal opportunities to all employees based on their professional qualifications and individual abilities, without any discrimination of religion, race, political or trade union beliefs or gender, adopting only criteria of merit and competence.
In relations with the Public Administration, GATE REI pays particular attention not only to full compliance with current regulations but also to the exact fulfillment of bureaucratic procedures relating to each act, behavior or agreement, so that every action undertaken by GATE REI is characterized by maximum transparency, fairness and legality.
During business negotiations, requests or commercial relations with the Public Administration, conduct must be maintained that does not improperly influence the counterparty’s decision.
Collusive practices and behaviors of any nature or form, and practices of active or passive corruption, are not permitted.
It is not permitted to examine or propose employment and/or business opportunities that may personally benefit Public Administration employees, or to solicit or obtain confidential information that may compromise the integrity or reputation of both parties.
During the execution of business relationships, what is established in the contract must be respected, avoiding unauthorized substitutions and putting in place adequate control and safeguard mechanisms, availing only of the cooperation of competent and suitable persons.
Should the Company use a consultant or a third party to be represented in relations with the Public Administration, the same directives valid for the Company’s employees apply to such parties and their staff.
GATE REI may accept requests for contributions only from entities and associations that are explicitly non-profit.
Furthermore, such contributions must be made in favor of activities of high cultural and/or social value consistent with the Company’s philosophy.
As for donations, GATE REI does not permit any form of gift that could be interpreted as exceeding normal business or courtesy practices, or in any case aimed at obtaining preferential treatment in the conduct of any activity connected to it.
Any form of gift to Italian and foreign public officials, or to their family members, that could influence their independence of judgment or induce them to ensure any advantage is also prohibited.
This rule applies to both promised or offered gifts and those received, meaning by gift any type of benefit (free participation in conferences, promise of a job offer, etc.).
Recipients must not carry out acts in which they have, even indirectly, interests potentially in conflict with those of GATE, meaning, by way of example only, personal or family interests of a financial or commercial nature with customers, suppliers or competitors.
GATE REI personnel refrain from giving and/or receiving gifts of any kind and value within work relationships, except for symbolic ones and in line with usual business practices, paying particular attention to relations with Public Administration employees. Consequently, stakeholders must refrain from giving gifts that could induce Recipients to behave in a manner contrary to the Company’s interests, including moral interests.
All shareholders, employees and collaborators of GATE REI must avoid conflicts of interest between their personal and family economic activities and the duties they hold within their organizational structure.
GATE REI’s activities constantly require the acquisition, storage, processing, communication and dissemination of data, information, documents and other data related to negotiations, administrative proceedings, financial transactions, know-how (contracts, deeds, reports, notes, studies, drawings, photographs, software, etc.) which, by contractual agreements, cannot be disclosed externally or whose inappropriate or untimely disclosure could harm corporate interests.
All GATE REI personnel are obliged to ensure and have ensured the confidentiality required by the circumstances for each piece of information learned by virtue of their job function.
The information, knowledge and data acquired or processed during one’s work or through one’s duties belong to GATE REI and may not be used, communicated or disclosed without specific authorization from the superior in a managerial position and in compliance with specific procedures.
GATE REI has meticulously applied the rules set out in Legislative Decree No. 196/2003 for the protection of data processed by GATE REI or by third parties, and/or generated or acquired internally and in business relationships, in order to avoid any misuse of such information.
GATE REI ensures that the processing of personal data carried out within its structures takes place with respect for the fundamental rights and freedoms, as well as the dignity of the data subjects, as provided by current legal provisions.
The processing of personal data is carried out in compliance with current regulations; data are stored for a period of time strictly necessary and relevant to the purpose of collection.
GATE REI adopts appropriate and preventive security measures for all processing in which personal data are collected and stored, in order to avoid risks resulting from events of destruction, loss, damage or unauthorized access.
GATE REI personnel acquire and process data only within specific procedures, and the storage and archiving of data are carried out in such a way as to prevent unauthorized persons from gaining knowledge of them.
GATE REI is committed to complying with and enforcing the rules also through the establishment of a Supervisory Body pursuant to Legislative Decree 231/2001, appointed concurrently with the adoption of the organization, management and control model.
The task of the Supervisory Body is to monitor and oversee the implementation of the Code of Ethics by the relevant parties, also by receiving reports and suggestions.
This Body may express binding opinions regarding any revision of the Code of Ethics of conduct or of the most relevant corporate policies and procedures, in order to ensure their consistency with the Code itself.
Interested parties may submit their reports regarding violations of the Code of Ethics through suitable communication channels set up by GATE REI.
Alternatively, all interested parties may report in writing, through the dedicated portal linked at the bottom of the company website, any violation or suspected violation of the Code of Ethics of conduct to the Body responsible for monitoring implementation of the Code itself, which will analyze the report, possibly hearing the author and the person responsible for the alleged violation, and will act to protect whistleblowers against any form of retaliation, understood as any act that could give rise even to the mere suspicion of being a form of discrimination or penalization. GATE REI ensures the confidentiality of the whistleblower’s identity, without prejudice to legal obligations.
In the event of ascertained violation of the Code of Ethics of conduct, the Supervisory Body reports the violation and any suggestions deemed necessary to senior management or the relevant functions, according to the seriousness of the violations.
The competent bodies define the measures to be adopted according to the regulations in force and the disciplinary system adopted by the Company, ensure their implementation and report the outcome to the Body responsible for monitoring the Code of Ethics of conduct.
In order to ensure maximum awareness of this Code of Ethics, GATE REI undertakes to disseminate it, by all means deemed most appropriate (including through its website), to the relevant parties, also through specific and adequate communication activities.
Violation of the provisions of this Code of Ethics will constitute a breach of the contractual obligations of the employment, functional or professional collaboration relationship, with all consequent effects of law and contract, including pursuant to Art. 2104 of the Civil Code.
In the event of any violations of this Code, GATE REI will apply the disciplinary sanctions provided for by the disciplinary code.
The Code of Ethics may be amended and supplemented by resolution of the Company’s Board of Directors, which will be duly communicated to the Recipients.
