This Ethical Code has been approved by the Board of Directors of GSR Technology Italy srl
Companies’ building blocks are People.
Ethics is an ensemble of behaviours and values that guide the conduct of an Individual within the community they belong to. Values that have been built throughout time: the institutions, the family, the civil society, other more complex realities such as Companies.
The embracement of companies towards their ethical and social duties has severely starkened over the course of the past decades. Ethical values can be considered as the fundamental principles by which firms and employees shape mutual relations.
The Ethical Code of a Company needs to include the behaviours of both a community and individuals, referring to the principles of: Equity and equality; Transparency; Honesty; Diligence; Impartiality; Privacy; Protection of the individual; Environmental protection.
These principles must also be taken into consideration when making a strategic decision about Customers and Suppliers.
Ethical companies that achieve successful relationships with customers and suppliers, strive to a mutual benefit. Their employees take responsibility for corporate conduct.
INTRODUCTION
THE VISION OF GSR TECHNOLOGY ITALY SRL
GSR Technology Italy srl is aware that the prestige of a company also derives from the attention towards the needs of the whole community, in addition to the expertise of its employees and the high-quality of the productservice provided to the customers.
The principles that have always guided the work of GSR Technology Italy srl are officially gathered in an Ethical Code of Conduct, believing that reliability builds up a day at a time by respecting norms and valuing the Individual.
This Ethical Code represents therefore a unique and identifiable element addressed to the market and third parties. Its knowledge and sharing are required by all those that operate within or with the company and constitute the common grounds of our business and the first step towards the pursuit of our Vision.
GSR Technology Italy srl strives to pursue the excellence in the markets of competence by a Sustainable Development, that is, by preserving the Environment and the Security of the involved people through a behaviour which responds to the norms of Social Ethics. The Company also aims to stand out and guarantee added value for the Employee, the Customer and, in general, for the Community.
PURPOSE AND SUBJECTS
The goal of this Ethical Code is that of depicting and explaining all the ethical and moral principles which underlie the business of GSR Technology Italy srl as well as the behavioural guidelines which need to be followed both within the Company (in the relationships between the employees) and without (in the relationships with the Institutions, the suppliers, the commercial partners, the political and labour unions, the information agencies (“Stakeholders”).
The observance of these principles is vital for the achievement of the mission of GSR Technology Italy srl and for the upkeep of its reputation in the socio-economic context in which it operates.
GSR Technology Italy srl firmly believes that every activity must be ethically carried out, in agreement with the principle declared by the 41st Clause of the Italian Constitution, according to which, the private economical initiative “cannot be carried out if against the social utility or if threatening security, liberty and human dignity”.
This Ethical Code is binding upon all managers and employees of GSR Technology Italy srl, as well as upon all those operating and collaborating, permanently or on a fixed term, on behalf of GSR Technology Italy srl (the “Subjects”).
The Ethical Code will be vastly widespread within the internal governance structure, but also widely disseminated externally by means of our website and social media channels too.
GSR Technology Italy srl commits itself to making sure by every other mean that the principles and limitations of the Ethical Code get duly divulged and applied.
1 GENERAL PRINCIPLES
The behaviour of the Subjects, at all company ranks, is ruled by the principles of legality, decency, nondiscrimination, privacy, diligence, and loyalty.
1.1 Legality
GSR Technology Italy srl operates in the maximum respect of the law and of this Ethical Code.
All Subjects must observe every applicable rule and constantly keep up to date with the legislative updates, even by making use of the formative opportunities offered by GSR Technology Italy srl.
GSR Technology Italy srl deems the transparency of financial reports and accounting a pivotal principle for the practise of its business and safeguard of its reputation.
1.2 Decency
Decency and moral integrity are indefectible duties for all Subjects.
While carrying out their work, the Subject must not accept donations, favours, or benefits of any sort (except for items whose value must not exceed 50,00€ - fifty euros), and, generally, must not accept any exchange to improperly accord advantages.
Likewise, Subjects must neither deposit money or material donation to third parties, nor offer avails or illicit benefits of any sort (except objects of modest value or commercial courtesy gift authorised by GSR Technology Italy srl) connected to the carried out activities that benefit GSR Technology Italy srl. The intrinsic belief of acting for the profit of the Company does not exempt the Subject from the duty of invariably respecting the rules and principles of this Ethical Code.
1.3 Non-discrimination
In the relations with Stakeholders and, in particular, in the selection and management of personnel, in the work organization, in the pick, selection and management of suppliers, as well as in the relations with the Authorities and Institutions, GSR Technology Italy srl prevents and repudiates any discrimination against age, sex, ethnicity, sexual orientation, health condition, political and union opinions, religion, culture and nationality of its interlocutors.
GSR Technology Italy srl, at the same time, supports integration by promoting intercultural dialogue and the protection of the rights of minorities and vulnerable individuals.
1.4 Privacy
GSR Technology Italy srl undertakes to ensure the protection and confidentiality of personal data of Subjects and Stakeholders, in compliance with all applicable legislation on the protection of personal data.
The Subjects are obliged not to use confidential information, learned from their work, for purposes unrelated to the exercise of such activity, and also obliged to always act in compliance with the confidentiality obligations assumed by GSR Technology Italy srl towards all Stakeholders.
In particular, the Subjects are bound to the utmost confidentiality on documents suitable for disclosing knowhows, transport information, commercial information and corporate transactions.
1.5 Diligence
The relationship between GSR Technology Italy srl and its employees is based on mutual trust: personnel is, therefore, required to work to promote the interests of the company, respecting the values set out in this Ethical Code.
Subjects must refrain from any activity that may conflict with the interests of GSR Technology Italy srl by waiving the pursuit of personal interests in conflict with the legitimate interests of the Company.
In cases where it is possible to represent the possibility of a conflict of interest, the Subjects are required to contact, without delay, their hierarchical superior so that the company can assess, and possibly authorize, the potentially conflicting activity.
In cases of infringement, the Company will take all appropriate measures to end the conflict of interest, reserving its own protection.
1.6 Loyalty
GSR Technology Italy srl and the Subjects undertake to achieve fair competition, in compliance with national and community legislation, in the knowledge that virtuous competition is a healthy incentive to innovation and development processes, also protects the interests of consumers and the community.
2 PERSONAL PROTECTION: RELATIONS WITH THE EMPLOYEES AND AMONGST COLLEAGUES
2.1 Personnel selection
The evaluation and selection of personnel are carried out according to correctness and transparency, respecting equal opportunities to combine the needs of GSR Technology Italy srl with the professional profiles, ambitions and expectations of candidates.
GSR Technology Italy srl undertakes to take any useful measure to avoid any form of favouritism in the process of personnel selection using objective and meritocratic criteria, respecting the dignity of candidates and in the interest of the good performance of the company.
The staff recruited, including through the implementation of this Ethical Code, will receive clear and correct information about the roles, responsibilities, rights and duties of the parties.
2.2 Personnel management
GSR Technology Italy srl protects and enhances its human resources, committing itself to maintaining the necessary conditions for professional growth, knowledge and skills of each person, carrying out appropriate further training and any initiative to that end.
GSR Technology Italy srl promotes the participation of workers in the life of the company, providing participatory tools able to collect the opinion and suggestions of workers, ensuring their widest participation.
Without prejudice to the maximum availability towards the Company, no worker may be obliged to perform duties, services or favours not due according to his employment contract and his role within the company.
The Company is firmly committed to countering bullying, stalking, psychological violence and any discriminatory or damaging behaviour of the person’s dignity inside and outside the company premises.
Relationships between employees must be conducted with loyalty, fairness and mutual respect, in compliance with the values of civil coexistence and the freedom of persons.
3 ENVIROMENTAL PROTECTION AND WORKSPACE
GSR Technology Italy srl is committed to providing its staff with a healthy, safe and respectful working environment.
Cleanliness and safety in the workplace are ensured both by strictly implementing the provisions of the law in force, and actively promoting the culture of cleanliness and safety through specific training programmes.
Staff training is a central element of the management system adopted.
GSR Technology Italy srl protects the health of its workers, also ensuring compliance with hygiene rules and health prevention.
GSR Technology Italy srl is attentive to the respect of the Environment: a reduction in the consumption of resources or pollutant emissions and waste can lead to a reduction in the impact on the environment.
4 COMPANY MANAGEMENT
4.1 Compliance with internal protocols
GSR Technology Italy srl believes that management efficiency and the culture of control are indispensable elements for achieving the objectives.
Subjects are required to strictly observe the procedures and instructions within the company.
Subjects must act according to their respective authorization profiles and must keep all appropriate documentation to keep track of actions taken on behalf of the company
4.2 Accounting management
In the accounting management activity, the Subjects are called to act in compliance with the principles of truthfulness, accuracy and transparency, so that the reputation of GSR Technology Italy srl is protected both internally and externally.
Compliance with these principles also allows the company to plan its operating strategies according to its real economic and financial situation.
All entries in the accounts must therefore be supported by complete, clear and valid documentation, avoiding any form of omission, falsification and/or irregularity.
In the case of financial or financial items based on valuations and estimates, their recording shall be based on criteria of reasonableness and prudence.
4.3 Assets protection
The Subjects carry out their functions trying to rationalize and limit the use of company resources.
Subjects are required to properly enforce security provisions to protect hardware devices from unauthorized access, that could seriously infringe the rights to the protection of personal data of the staff and customers of GSR Technology Italy srl.
4.4 Communication
GSR Technology Italy srl provides Stakeholders with appropriate communication tools through which they can interact with the company to forward requests, ask for clarification or make complaints.
GSR Technology Italy srl promotes an effective corporate communication able to put the company in contact with civil society, to receive requests, needs and needs of the community and to spread its values and its mission.
The information provided to Stakeholders is complete and accurate so that Subjects can make correct and informed decisions.
The advertising promotion of GSR Technology Italy srl respects ethical values, protecting minors and repudiating vulgar or offensive messages.
5 RELATIONS WITH THE EXTERIOR
5.1 Relations with the Authorities and Public Administrations
Relations with the Authorities and Public Administrations must be marked by maximum clarity, transparency and collaboration, in full respect of the law and according to the highest moral and professional standards.
The Subject, unless expressly authorised, cannot report in the name and on behalf of GSR Technology Italy srl to the Authorities and to the Public Administration.
In their relations with the Public Officials, the Public Service Officers, and the Public Administration in general, the authorized Subjects will comply with the highest levels of correctness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any undue advantage for themselves or for GSR Technology Italy srl.
In this regard, the authorized Subjects will be required to strictly observe the provisions of this Code, as well as the directives issued by the management of GSR Technology Italy srl.
5.2 Relations with political and trade union organisations
GSR Technology Italy srl does not favour or discriminate against any political or trade union organization.
The Company shall refrain from making any undue contribution, in any form whatsoever, to parties, trade unions or other social groupings, unless specific exceptions are made and always within the limits of what is permitted by the rules in force.
The Subjects are obliged to refrain from any direct, indirect or purported pressure on politicians or trade union representatives.
5.3 Relations with customers and suppliers
The Subjects shall deal with third parties with courtesy, competence and professionalism, in the belief that their conduct depends on the protection of the image and reputation of the company and consequently the achievement of business objectives.
In particular, the Subjects shall refrain from any form of unfair or misleading conduct that may induce customers or suppliers to rely on unfounded facts or circumstances.
The Subjects are required to engage consistently to offer timely and high-quality services to customers, trying to limit any form of disruption or delay to maximize customer satisfaction.
Relationships with suppliers are based on loyalty, fairness and transparency.
The choice of suppliers is made based on objective criteria of economy, opportunity and efficiency.
The choice of suppliers is precluded on a purely subjective and personal basis or, in any case, by virtue of interests conflicting with those of the company.
The Subjects must put in place every possible control so that suppliers and customers are also able to comply with the fundamental ethical principles set out in this Ethical Code.
6 INTERNAL CONTROL SYSTEM
Compliance with the requirements of this Code is entrusted to the prudent, reasonable and careful supervision of each of the Subjects, within their respective roles and functions within the company.
All Subjects are invited to report to their immediate superior the facts and circumstances potentially contrary to the principles and prescriptions of this Ethical Code.
The management of GSR Technology Italy srl and the bodies of competence take all necessary measures to end the violations, being able to resort to any disciplinary measure in compliance with the law and the rights of workers, including trade union rights.
7 GUIDELINES FOR THE SANCTION SYSTEM
The internal control system adopts tools and methodologies aimed at hindering potential business risks, to ensure compliance not only with laws, but also with internal regulations and procedures.
The violation of the principles established in the Code and in the procedures indicated in the internal controls jeopardises the fiduciary relationship between the Company and its directors, employees, consultants, collaborators in various ways, customers, suppliers, business and financial partners.
Such violations will therefore be immediately prosecuted by GSR Technology Italy srl in an effective and timely manner, through the adoption of appropriate and proportionate disciplinary measures.
The effects of violations of the Ethical Code and internal protocols must be considered by all those who, in any way, maintain relations with GSR Technology Italy srl.
Depending on the seriousness of the conduct committed by the person involved in one of the illegal activities set off by the Code, GSR Technology Italy srl will immediately take the appropriate measures, regardless of whether the judicial authorities may prosecute or not.
Notwithstanding the foregoing, a conduct in violation of the Code of Ethics constitutes:
- serious breach of obligations for employees (workmen, clericals, and managerial staff), with the sanctions imposed, depending on the seriousness, by the CCNL of one’s category (verbal reprimand, written reprimand, fine not exceeding three hours' pay, suspension from work and pay-up to a maximum of three working days, just cause dismissal or dismissal for cause); in the case of pending prosecution, that is, the enforcement of a measure restricting the personal freedom of the employee, before taking disciplinary action, the sanction of suspension from service and suspension from remuneration may be adopted for the duration corresponding to the outcome of the criminal prosecution or until the end of the duration of the measure restricting personal liberty;
- just cause for dismissal of directors;
- cause of immediate termination of the work relationship, in the most serious cases, for external collaborators and para-subordinates;
- cause of immediate termination of the relationship, in the most serious cases, for suppliers, contractors and subcontractors.
The identification and application of sanctions will always consider the general principles of proportionality and adequacy to the alleged infringement.
In all these cases, GSR Technology Italy srl also reserves the right to carry out all the actions it deems appropriate for the compensation of the damage suffered because of the behaviour in violation of the Ethical Code.