ETHICS and TRANSPARENCY
Whistleblowing
DMG Spa has always promoted its ethical values with integrity and transparency.
Since December 2023, in compliance with Legislative Decree of March 10, 2023, No. 24, DMG Spa has also established a “Whistleblowing Committee” committed to ensuring that its employees and partners have the opportunity to report, with the guarantee of total confidentiality, illicit conduct and/or irregularities within the workplace that may constitute violations of laws or regulations, threats to the public interest, or severe situations endangering public health and safety.
Examples of misconduct that may be reported:
• Corruption
• Discrimination and harassment in the workplace
• Violations of the law and criminal offenses
• Human rights violations
• Active and passive corruptibility
• Poor administration or mismanagement
• Insider trading
• Improper use of data
MAKING A REPORT
Any suspected violations of laws, DMG corporate procedures must be reported. We have a policy that does not tolerate any form of retaliation.
Reports can potentially be made by all those who come into contact with DMG SPA (direct and indirect workers, suppliers, customers, etc.), with the assurance of confidentiality during the reporting process.
For a report to be considered regular, it must occur during the course of the relationship, and the reporter must have become aware of it in the course of performing their duties and decide to communicate it to the designated authorities to protect the collective interest.
Reports, as per articles 4 and following of Legislative Decree 24/2023, can be made through the following communication channel:
https://digitalroom.bdo.it/DMG
(The hyperlink above has been deliberately disabled in order to ensure maximum privacy and non-traceability, in compliance with current regulations.)
@Whistleblowing is a simple and immediately usable platform, accessible from any device (PC, tablet, smartphone)
@Whistleblowing adopts the highest security measures required by the Data Protection Authority, thereby ensuring the confidentiality and anonymity of the Reporter, as well as the data and documents at every stage of the process.
As required by law, the report must be as detailed as possible and provide the greatest number of elements known to the reporter, useful for proceeding with the necessary verifications and controls, also for the purpose of identifying the authors of the alleged unlawful conduct.
To this end, the report should preferably include the following elements:
- Personal details of the Reporter
- Role or function performed within the Institute
- Clear and complete description of the facts being reported
- If known, the circumstances of time and place where the events occurred
- Indication of any other subjects that may identify the person(s) who carried out the reported actions
- Identification of any other sujects who mau provide information on the reported facts
- Furthermore, the reported illicit conduct must pertain to situations directly known to the subject ‘in the course of employment’, thus certainly including information learned through the office held, as well as news acquired on occasion or due to the performance of work duties
Code of Ethics
INTRODUCTION
The Code of Ethics defines the commitments and ethical responsibilities in the conduct of business and corporate activities of D.M.G. S.p.A., encompassing the values and principles that should be adopted in the context of their respective roles and work activities by Directors, Auditors, Employees, and, in general, by all those who operate with the Company and/or have legal relations with it, regardless of the nature of their relationship.
The Code of Ethics, therefore, constitutes a charter of fundamental rights and duties, defining the ethical-social responsibilities (both internally and externally) of the Company and the values it embraces. As a code of conduct, the Code aims to clearly define the set of values and principles that D.M.G. S.p.A. adheres to in pursuing its goals, compliance with which is essential for the proper performance of its activities, as well as to preserve its reliability, reputation, and image.
The adoption of the Code is an expression of a corporate environment that aims first and foremost to satisfy, in the best possible way, the needs and expectations of those who come into contact with D.M.G. S.p.A., aiming to recommend and promote a high standard of professionalism in the conduct of corporate activities, while prohibiting all behaviors that are in conflict, primarily with the prevailing legislation, but also with the values embraced by D.M.G. S.p.A., such as honesty, moral and personal integrity, transparency, reliability, a sense of responsibility, respect for confidentiality and privacy, the protection of health and safety in the workplace, and transparent competition in the market by all involved parties.
The creation and dissemination of corporate values cannot be separated from an actual respect for the fundamental principles mentioned above, and the provisions contained in this Code of Ethics therefore aim to indicate some important corporate values and rules of conduct, serving to safeguard the reputation and image of D.M.G. S.p.A., to which both the company’s internal staff and collaborators, suppliers, and those bound by close legal relationships (hereinafter also referred to as “recipients”) must conform.
For the reasons stated above, the Code of Ethics is distributed within D.M.G. S.p.A. and made available to all employees, collaborators, consultants, partners, and suppliers who collaborate with the Company in any capacity, so that they observe its contents.
It is the responsibility of each employee to consult their superior for any clarification regarding the interpretation or application of the rules of conduct contained in this document or in other directives issued by the competent functions of D.M.G. S.p.A..
Given this, it is a natural consequence that compliance with the provisions of this Code is considered an integral part of the contractual obligations undertaken by the company’s personnel, also under the terms and effects of Art. 2104 of the civil code and other rules concerning employment relations and respect for contractual and regulatory obligations.
Violation of the norms of the Code may therefore constitute a serious breach of the obligations deriving from the employment contract and a source of civil wrongdoing, with all consequent personal responsibility and may lead to appropriate disciplinary measures against the employees responsible, according to the Disciplinary System adopted by the same.
Administrators, employees, collaborators, consultants, partners, and suppliers are in turn required to rigorously observe this Code of Ethics, as non-compliance constitutes a violation of the “Model of organization, management, and control” adopted pursuant to Art. 6 of Legislative Decree 231/01, of which this Code forms an integral part along with the set of company procedures, adopting the penalties provided therein and with the possibility of residual protection provided by current, including contractual, legislation.
Article 1 - RECIPIENTS, DUTIES AND RESPONSABILITIES
The recipients of the ethical code include all employees, without any exception, and all those who, directly or indirectly, on a stable or temporary basis, establish relationships or connections with the Company and work to pursue its objectives.
The ethical code must be respected by all parties involved in the legal acts established by the Company for the conduct of its activities. This Ethical Code must therefore be observed and enforced by:
• Administrators and Employees of D.M.G. S.p.A.
• Collaborators and Consultants who act in any capacity in the interest of D.M.G. S.p.A.
• Partners and Suppliers of D.M.G. S.p.A.
The recipients identified above and those who operate on behalf of D.M.G. S.p.A., for any reason, are obliged to know and respect this Code and must comply with the laws and regulations in force in Italy and in the country where they are conducting their activities on behalf of the Company.
Employees and collaborators of D.M.G. S.p.A. are required to refrain from behaviors contrary to the aforementioned rules and should refer to their supervisor or the designated Supervisory Body for clarifications or complaints, as well as collaborate with the structures appointed to verify violations.
All counterparties must be informed of the existence of behavioral norms and must respect them, under penalty of the consequences established by the contract.
All those who hold positions of responsibility in D.M.G. S.p.A. (the senior figures) are required to set an example for their employees and collaborators, to guide them in complying with the Code, and to carefully select employees and collaborators who ensure maximum commitment in respecting the rules.
They must also report all useful information about potential deficiencies in controls, suspicious behaviors, etc., to the designated Supervisory Body and modify the control systems of their function based on indications from the Supervisory Body.
No objective of D.M.G. S.p.A. can be pursued or achieved in violation of the laws and regulations in force.
Honesty is the fundamental principle for all the Company’s activities, its initiatives, its reports, and its communications and constitutes an essential value of organizational management.
Relationships with all subjects at all levels must be characterized by criteria and behaviors of correctness, collaboration, loyalty, and mutual respect.
This Code is valid both in Italy and, possibly, abroad.
Article 2 - USE OF INFORMATION
All information about the Company and/or its Clients that is not public domain and known to a Recipient through their role or relationship of work, consultancy, and/or collaboration must be considered confidential. Therefore, it should be used only for carrying out one’s work activities and/or assigned duties, avoiding any behavior, either with colleagues or third parties, that might reveal non-public proprietary information of the Company and/or its Clients, taking all precautions to prevent the undue dissemination of such information.
Administrators and Employees must not use or allow the use of information that is not in the public domain regarding the Company.
Any information in possession of D.M.G. S.p.A. must be handled respecting the confidentiality and privacy of the involved parties. Should staff receive confidential information, they must manage it with the utmost confidentiality to prevent the Company from being accused of misappropriation and misuse of such information.
Company personnel are not allowed, unless formally authorized by the Company, to receive and use confidential data and information unless D.M.G. S.p.A. has previously fulfilled the regulatory obligations towards the third parties involved in the use of such information. All the above in compliance with the current data protection regulations.
External communication must be truthful, transparent, and consistent with the Company’s policies. In particular, D.M.G. S.p.A. prohibits Administrators, employees, and third parties acting on behalf of the Company from presenting materially false facts, omitting to communicate information on the economic, asset, or financial situation of the Company as required by law, national, community, and international regulations, and from concealing data or information that could mislead the recipients.
Employees called to provide external information about the Company’s objectives during participation in conferences, public interventions, and the drafting of publications in general, are required to obtain prior authorization from Administrators, agreeing on the content with them and with the heads of the relevant business functions.
Employees shall refrain from behaviors and statements that could damage the Company’s image, which they should instead promote through the correctness of the behavior required of them.
All employees must use the computer tools available to them exclusively as a work tool, respecting the current legislation and the relevant company procedures.
Article 3 – RELATIONS WITH THE PUBLIC ADMINISTRATION AND THIRD PARTIES
Activities aimed at the acquisition of contracts and the awarding of tenders must be carried out in accordance with correct economic principles, within the regular market context, in fair competition with other contenders, and always in compliance with the applicable laws and regulations.
Relations with clients, both public and private, and with contractors are characterized by a sense of responsibility and a spirit of collaboration. No claims will be made against them unless they are deemed legitimate and included in the contracts signed.
D.M.G. S.p.A., consistent with the values of honesty, fairness, and transparency that guide its operations, implements all necessary measures to prevent and avoid occurrences of corruption or conflicts of interest.
Relations with public institutions and third parties will be maintained only by the designated functions or with their authorization.
Recipients must not, under any circumstances, give or promise to third parties any sums of money or other benefits in any form and manner, even indirectly, to promote or favor the interests of the Company, nor can they accept for themselves or others such gifts or promises to promote or favor third-party interests in relations with the Company.
In particular, in relations with the Public Administration, it is forbidden to give, offer, or promise money or other benefits, such as services, performances, or favors that could reasonably be interpreted as exceeding normal courtesy practices, or to exert unlawful pressures on public officials, public service managers, executives, officials, or employees of the Public Administration or of public service concession holders, or their relatives or cohabitants, both Italian and foreign, aimed at inducing the counterparty to perform any act contrary to, or in accordance with the duties of their office.
In relations with the Public Administration or public service concessionaires, the Company should not be represented by third parties when this could create conflicts of interest.
During business relations with the Public Administration or public service concessionaires, recipients must refrain from soliciting or obtaining confidential information that could compromise the integrity or reputation of both parties.
An employee who receives explicit or implicit requests or offers of such benefits must immediately inform their direct supervisor and, for knowledge, the Supervisor of the Compliance Body under Legislative Decree 231/01, suspending any relationship with the interested third parties pending specific instructions. Exceptions to these prescriptions are only for gifts of symbolic value, when they are solely attributable to acts of courtesy within the context of proper business relations and are not expressly prohibited as they conflict with legal norms or regulations, including internal ones.
An employee who, in carrying out their activities always related to the corporate purpose and in line with company policies, finds themselves in situations that might, or they believe might, due to potential conflicts of interest, concurrence of personal interests, or for any other reason, influence, or even appear to influence, relations with third parties, must immediately inform their direct supervisor.
The Company also supports social responsibility initiatives, including through the provision of sponsorships or contributions to foundations, institutions, and organizations dedicated to improving living conditions and promoting culture and solidarity in the community in which it operates.
Sponsorships and donations to societies or associations, even unrecognized ones, are duly authorized and clearly identify the interested counterparts and the motivations underlying the provision; the transfer of economic value is carried out through authorized intermediaries, ensuring traceability based on suitable documentation.
It is not allowed to make false statements to public bodies, national or community, in order to obtain public grants, contributions, or subsidized financing, or to obtain concessions, authorizations, licenses, or other administrative acts.
It is forbidden to use sums received from public bodies, national or community, as grants, contributions, or financing, for purposes other than those for which they were assigned.
It is prohibited to alter the functioning of a computer or telematic system of the Public Administration or manipulate the data contained therein in order to gain undue profit.
Relations with third parties, both nationally and internationally (clients, suppliers, external collaborators, partners, competitors, media, authorities, and public administration), must be characterized by loyalty and fairness, in the protection of corporate interests.
Loyalty and fairness must also be demanded from third parties who will be duly made aware of the Ethical Code of D.M.G. S.p.A.
D.M.G. S.p.A. does not provide contributions to support parties, movements, committees, and political and union organizations, nor to their representatives.
Article 4 – RELATIONSHIPS WITH SUPPLIERS, CUSTOMERS, AND AFFILIATES
The selection of suppliers and external collaborators (including consultants, agents, contractors) for the purchase of goods and services is based on assessments that allow reliance on suppliers of proven quality, integrity, reliability, and cost-effectiveness. The purchasing processes are based on respect for the principles and laws that protect competition, ensuring transparency and efficiency in the selection process. The fees and amounts paid to suppliers under any title are in line with market conditions or otherwise justified and verifiable. Each Recipient of this Code who participates in these processes is required to:
• act with objective and documentable criteria;
• not accept any form of personal benefit;
• verify, through appropriate documentation, that the parties involved have adequate means and resources for the needs and image of the Company;
• ensure the traceability of choices by preserving documents that prove compliance with internal procedures and the purposes of the purchase;
• promptly report any behavior potentially contrary to the Principles and Values of the Code;
• base the relationship with colleagues on values of civil coexistence and respect, avoiding any form of discrimination.
The Company will terminate the initiation or continuation of any relationship if there are suspicions of affiliation or facilitation of criminal organizations. In contractual relationships with its suppliers, the Company requires a commitment to share and respect the principles stated in this Code. Violation of the principles established in it constitutes a breach sufficient to terminate the existing relationship.
The Company aims to meet the expectations of its customers by providing high-quality products and/or services in compliance with the regulations protecting competition and the market, and by conducting itself with values of fairness, honesty, and professionalism.
In relationships with customers, the Recipients, as far as their competence and the assignments conferred to them, commit to not arbitrarily discriminate against customers, respect commitments and obligations undertaken, provide accurate, complete, and truthful information, adhere to truth in advertising or other communications, and avoid any deceptive, elusive, or unfair practices.
No form of gift or free benefit, promised, offered, or received, that may be interpreted as exceeding normal commercial or courtesy practices, or otherwise aimed at acquiring favorable treatment in the conduct of any operation related to the activity of the Company, is permitted. This rule admits no exceptions, even in countries where offering valuable gifts to business partners is considered customary.
RELATIONSHIPS WITH AFFILIATES
All relationships with affiliated companies are managed in full compliance with current regulations, as well as in observance of the principles outlined in this Ethical Code.
The relationships between companies and the information of each company intended for the preparation of the consolidated financial statements respond to criteria of transparency, correctness, effectiveness, and traceability of the underlying economic relationships and related financial flows.
The relationships between companies and the information of each company intended for the preparation of the consolidated financial statements respond to criteria of transparency, correctness, effectiveness, and traceability of the underlying economic relationships and related financial flows.
Article 5 – RECORD-KEEPING, ACCOUNTING ENTRIES, AND CORPORATE OFFENSES
Transparency and truthfulness in accounting are indispensable values and standards.
Accounting transparency is based on the truth, accuracy, and completeness of the documentation of every activity and its related accounting transactions. Therefore, every transaction must be supported by documentation that justifies the activity performed, allowing for accounting registration, detailed reconstruction, and identification of different levels of responsibility.
All actions and operations of the Company must be adequately recorded, and it should be possible to verify the decision-making, authorization, and execution processes ex post.
Every operation must have adequate documentary support to allow for controls at any time, which attest to the characteristics and motivations of the operation and identify the individuals who authorized, carried out, recorded, and verified the operation.
Accounting records must be maintained accurately, completely, and timely in accordance with the company’s accounting procedures, to faithfully represent the financial/asset situation and management activities.
No false or artificial accounting entry may be included in the Company’s records for any reason.
No employee may engage in activities that result in such offenses, even if requested by a superior.
All employees involved in accounting must ensure maximum cooperation, completeness, and clarity of the information provided, as well as the accuracy of the data and processes.
Financial statements and corporate communications required by law and applicable special regulations must be clearly drafted and correctly and truthfully represent the financial and asset situation of the company.
Reports, communications, and filings with the Business Registry that are mandatory for the Company must be made by individuals identified by the laws in a timely, truthful manner and in compliance with current regulations.
It is expressly forbidden to prevent or obstruct, through the concealment of documents or other suitable schemes, the performance of legally prescribed control or audit activities.
It is also forbidden to present to public supervisory authorities material facts that are untrue, even if under evaluation, regarding the economic, asset, or financial situation of the Company, or to omit the representation of facts that must be communicated.
This principle must also be observed concerning information related to assets owned or managed on behalf of third parties.
It is prohibited to obstruct, in any form, the functions of the public supervisory authorities during audits and/or inspections.
It is prohibited to carry out reductions in share capital, mergers, or splits in violation of legal provisions protecting creditors.
Any type of operation that may cause harm to shareholders or creditors is prohibited.
If employees notice or become aware of falsifications, omissions, or neglect in accounting, or in the documentation on which the accounting records are based, or of any violation of the aforementioned rules, they must immediately report it to their superior and for knowledge to the Head of the Supervisory Body under Legislative Decree 231/01.
In the case of deliberately unfounded reports, the employee will be subjected to disciplinary proceedings in the manner and within the terms provided in the “Model” according to Legislative Decree 231/01.
Article 6 - FALSIFICATION OF BANKNOTES, COINS, PUBLIC CREDIT CARDS, STAMP VALUES, AND WATERMARKED PAPER
It is prohibited to falsify, circulate, purchase, or sell banknotes, coins, public credit cards, stamp values, and watermarked paper for the benefit and/or advantage of the Company.
Anyone who receives in the course of their activities counterfeit or stolen banknotes, coins, or public credit cards as payment is obliged to inform their superior so that appropriate reports can be made.
Article 7 – HUMAN RESOURCES MANAGEMENT, HEALTH AND SAFETY AT WORK
Human resources are an indispensable element for the existence, development, and success of the company.
The evaluation of personnel that D.M.G. S.p.A. may potentially hire is based on the correspondence of the candidates’ profiles to the expected ones and to organizational needs, respecting the principles of impartiality and equal opportunities for all interested parties.
When a collaboration begins, the employee/collaborator must receive comprehensive information about the characteristics of the tasks and the role, regulatory and remunerative elements, and regulations and behaviors for managing risks related to health, safety, and privacy.
They must also explicitly accept their commitments arising from this ethical code.
Work relations among employees and between different hierarchical positions within D.M.G. S.p.A. must occur according to principles of civil coexistence, mutual respect, and ensuring the protection of individual rights, and must be based on principles of loyalty and fairness.
Each Manager is required to exercise the powers connected to their corporate position with objectivity and balance, caring for the professional growth of their collaborators and improving working conditions.
The professionalism and dedication of employees are fundamental values for achieving corporate objectives.
The Company is committed to developing the skills and stimulating the capabilities and potential of its employees, so that they find full realization in achieving goals.
The Company offers equal employment opportunities to all employees based on specific professional qualifications and performance capabilities, without any discrimination as the competent functions select, hire, and manage employees based on criteria of competence and merit, without any consideration of race, religious belief, gender, age, descent, personal disabilities, length of service, fully respecting the rights of the person and the laws and regulations in force, with particular attention to the current legislation on child labor and the employment of immigrant workers.
The Company is committed to hiring staff with a regular employment contract, in line with the professional profiles of the different company areas and in accordance with current legislation and in particular the principles of the Civil Code and the Workers’ Statute.
No form of “under-the-table” work or payment is tolerated.
The company commits, in compliance with current legal provisions, not to establish any working relationship with individuals without a residence permit and not to carry out any activity aimed at facilitating the illegal entry into the state territory of clandestine individuals.
The competent functions monitor to ensure that the work environment is, in addition to being adequate from the standpoint of safety and personal health, free of prejudices and that every individual is treated with respect, without any intimidation and respecting their moral personality, avoiding illicit conditioning and undue discomfort.
The Company demands that in internal and external work relations, no one is placed in a state of subjugation through violence, threat, deceit, abuse of authority, or taking advantage of a situation of physical or psychological inferiority, or a situation of need.
D.M.G. S.p.A. disapproves of any form of harassment, including sexual harassment.
In particular, any behavior that may constitute moral violence and/or psychological persecution aimed at offending the personality, dignity, and psycho-physical integrity of employees, as well as endangering their employment or degrading the work environment (mobbing), is prohibited.
The employee/collaborator who believes they have been subjected to harassment or discriminated against for reasons related to the sexual sphere, race, health status, nationality, political opinions, religious beliefs, etc., or any other unjustified reason based on objective and reasonable criteria, can report the incident to the competent function, which will carefully evaluate the actual violation of this code, reporting it to the Supervisory Body.
The Company does not favor or discriminate against any political or trade union organization.
The Company refrains from providing any undue contributions in any form to parties, unions, or other social formations, except for specific derogations and always within the limits allowed by the current regulations.
Recipients are required to abstain from any direct, indirect, or pretended pressure on political figures or trade union representatives.
Article 8 - PROTECTION OF HEALTH AND SAFETY AT WORK
D.M.G. S.p.A. commits to pursuing objectives for improving the safety and health of workers as an integral part of its activity and as a strategic commitment in relation to the more general purposes of the Company and, in compliance with current regulations, guarantees a work environment that is safe and healthy for employees, adopting all necessary technical and health measures, including training.
To this end, the Company:
• Commits to spreading and consolidating a culture of safety and health at work by developing awareness of risks and promoting responsible behaviors by all collaborators;
• Provides institutional training, delivered at certain times in the company life of the employee, and recurring training aimed at operational staff;
• Promotes and implements every initiative aimed at minimizing risks and removing causes that may jeopardize the safety and health of employees, through technical and organizational interventions, including the introduction of a risk management system, safety, the resources to be protected, and by implementing an effectively efficient system of monitoring the adoption of findings and prevention measures, overseen by sanctions that can extend to expulsion from the employment relationship.
Personnel must take care of their own health and safety and that of other people present at the workplace, who may be affected by their actions or omissions, in accordance with the training, instructions, and means provided by the employer.
For this reason, the use of drugs, abuse of alcohol, or taking illegal drugs will not be tolerated in the workplace.
Recipients are thus committed to respecting and ensuring respect, within their competence, for all the preventive and safety measures put in place.
Every employee must be aware of the legal implications related to their activity; management is required to provide each employee with necessary information and instructions.
The dissemination of company information and training to Employees, including that aimed at promoting the knowledge of ethical principles and norms, must be adequate, correct, and comprehensive.
Article 9 – ENVIRONMENT
The Company respects the principle of environmental protection and contributes positively to its protection and safeguarding by seeking the most suitable solutions to reconcile business needs with responsible resource use, reduction of energy consumption, and proper management of potential emissions into the atmosphere, ensuring full compatibility of its activities with the territory and the surrounding environment.
D.M.G. S.P.A. manages its activities striving for excellence in environmental protection, aiming for continuous improvement of its environmental performance, committing to comply with existing environmental regulations, promoting awareness and employee participation in the environmental safeguarding process. To this end, it commits to conducting business activities with full respect for the environment, understood in the broadest sense, especially:
• Considering the environmental impact of new activities and production processes;
• Using natural resources responsibly and consciously;
• Developing a relationship of constructive collaboration, characterized by maximum transparency and trust, both internally and with the external community and institutions in managing environmental issues;
• Maintaining high safety and environmental protection standards through the implementation of effective management systems.
• Using natural resources responsibly and consciously;
• Developing a relationship of constructive collaboration, characterized by maximum transparency and trust, both internally and with the external community and institutions in managing environmental issues;
• Maintaining high safety and environmental protection standards through the implementation of effective management systems.
Article 10 – CONFLICT OF INTEREST
Recipients in the performance of their duties must pursue the objectives and interests of the Company, avoiding situations and activities that may conflict with these principles.
The personnel of D.M.G. S.P.A., in carrying out their activities, may not:
• Engage in work activities for competitors;
• Provide, without the Company’s consent, their professional services to competing companies as a consultant, collaborator, member of the Board of Directors, or Audit Committee;
• Represent, act, and work on behalf of a supplier or customer of the Company.
• Provide, without the Company’s consent, their professional services to competing companies as a consultant, collaborator, member of the Board of Directors, or Audit Committee;
• Represent, act, and work on behalf of a supplier or customer of the Company.
Personnel may not engage in activities during their working hours that are not consistent with their duties and organizational responsibilities.
Employees who find themselves in a situation of conflict of interest, even potential, must immediately notify the Supervisory Body, which will evaluate the appropriate conduct to be followed.
The use of company assets for personal use and interest is not allowed, except in cases expressly provided for by the company and regulated by specific regulations.
Employees who find themselves in a situation of conflict of interest, even potential, must immediately notify the Supervisory Body, which will evaluate the appropriate conduct to be followed.
The use of company assets for personal use and interest is not allowed, except in cases expressly provided for by the company and regulated by specific regulations.
Article 11 – COMPANY MEASURES
The Company intends to sanction behaviors of personnel that are not compliant and consistent with the values and principles of the Ethical Code, reserving the broadest protection of its interests according to the severity of the infractions committed under the Disciplinary Code adopted in accordance with current regulations.
Article 12 - DUTY TO REPORT
Any behavior contrary to this code must be reported to the Supervisory Body under legislative decree 231/01. Reporters will be protected against any form of retaliation, discrimination, or penalization; confidentiality of the reporter’s identity will also be guaranteed, subject to legal obligations and the protection of the rights of the company or individuals wrongfully accused and/or maliciously.
Article 13 - IMPLEMENTATION OF THE ETHICAL CODE
The commitment and collaboration of the entire corporate structure are the sine qua non conditions for correct and effective application of this Code. The task of overseeing compliance with this Code, reporting at least once a year to the Board of Directors, is assigned to the Supervisory Body. To ensure the correct implementation of this Code, D.M.G. S.P.A. commits to making known the values and principles it contains, in suitable ways, to all interested parties so that they are applied in social management.
All employees, collaborators, members of corporate bodies, auditors, consultants, and more generally all third parties who enter into business relations with the company must be aware of the Code and commit to following the prescriptions and rules it contains.