Code of Ethics

Date of first implementation: 01.01.2018

Date of last revision: 01.06.2022

SUMMARY

Article 1 – Scope

Article 2 – Circulation

Article 3 – Obligations of Shareholders, Employees and Contract Workers

Article 4 – Responsibility

Article 5 – Doubts on interpretation

Article 6 – The Guiding Values of Studio Torta

Article 7 – Duty of diligence

Article 8 – Duty of honesty

Article 9 – Duty of confidentiality

Article 10 – Duty of business propriety

Article 11 – Duty of impartiality

Article 12 – Harassment at the workplace

Article 13 – Behaviour in Social life

Article 14 – Client relations

Article 15 – Supplier relations

Article 16 – Relations with Public Institutions

Article 17 – Relations with Professional Associations

Article 18 – Professional training

Article 19 – Use of company assets

Article 20 – Use of the Internet and email

Article 21 – Listening and dialogue

Article 22 – Cohesion

Article 23 – Initiatives to reconcile work and private commitments

Article 24 – The Board of Directors

Article 25 – Health and Safety

Article 26 – Environmental protection

Article 27 – Violation of the provisions of the Code of Ethics

Article 28 – Advice and recommendations

Article 1 – Scope

The Code of Ethics identifies the Guiding Values of Studio Torta and defines the ethical-social profile that must guide the work of each Shareholder, Employee and Contract Worker for its functioning. The Code of Ethics rules apply to all Shareholders, Employees and Contract Workers, each of whom must actively contribute to its implementation and report any shortcomings. Studio Torta facilitates and promotes knowledge of the Code of Ethics and encourages constructive contributions to its contents. The Code of Ethics is intended to provide Shareholders, Employees and Contract Workers with a concise tool to understand the conduct to be held and the conduct to be avoided in the course of their work.

Article 2 – Circulation

The Code of Ethics is made known to all Clients and Suppliers of Studio Torta by publishing it on its website. The Code of Ethics is also made easily accessible to all Shareholders, Employees and Contract Workers in the most appropriate ways – also through information technology.

Article 3 – Obligations of Shareholders, Employees and Contract Workers

The Shareholders, Employees and Contract Workers of Studio Torta: must know the rules of the Code of Ethics must refrain from any conduct contrary to the Code of Ethics; must promptly notify their manager or the manager of the business function involved of any violation of the Code of Ethics detected directly and any request made to them to violate the Code of Ethics; must cooperate in the verification of possible violations of the Code of Ethics.

Article 4 – Responsibility

The Code of Ethics is also based on non-juridical norms and is aimed at the moral and professional sensitivity of individuals. Shareholders, Employees and Contract Workers of Studio Torta have the moral responsibility for the circulation and application of the values expressed by the Code of Ethics in all the areas in which they are involved.

Article 5 – Doubts on interpretation

Shareholders, Employees and Contract Workers of Studio Torta, in any cases of doubt on any matter relating to the application of the Code of Ethics rules, must contact the Personnel Department to obtain clarification on the conduct to be held.

Article 6 – The Guiding Values of Studio Torta

The Guiding Values of Studio Torta, from which the daily operation of all the components of the Studio Torta organization must draw inspiration, are based on moral qualities such as integrity, fairness, independence and confidentiality of Shareholders, Employees and Contract Workers:

TEAMWORK

Being a team means producing synergy from individuality, respecting others, drawing richness from diversity.

INNOVATION

We believe and invest in innovation because we believe that continuous improvement benefits our team and all our stakeholders.

CURIOSITY

Curiosity helps us understand your needs and the deep changes of the market and drives us to find new solutions for the best protection of your assets and more efficient services.

RESILIENCE

We face daily challenges firmly. We are aware of our experience and our team’s potential, and trust to find the best solution in every context.

RESPONSIBILITY

Responsibility towards the Company, the market and the Clients. The care and attention we put into our work is the guarantee of our reliability.

Article 7 – Duty of diligence

The Shareholders, Employees and Contract Workers of Studio Torta act and operate in compliance with the rules and the function assigned to them, directing their conduct to the attainment of the objectives of Studio Torta.

Article 8 – Duty of honesty

Shareholders, Employees and Contract Workers of Studio Torta work with Justice and Honesty and refrain from initiating any situations from which they may gain personal benefit, advantages or convenience. The only profit deriving directly or indirectly from the work is the remuneration and the fees paid by Studio Torta and/or known to it. For the Code of Ethics, Shareholders, Employees and Contract Workers of Studio Torta are prohibited from:

  • engaging in practices of corruption, unlawful favours, collusive behaviour, and soliciting illegal actions (directly and/or through third parties);
  • accepting gifts or other benefits from subjects in any way interested in the work of Studio Torta;
  • promising or paying to third parties sums of money, goods in kind, or benefits of any entity or value, to promote or favour the interests of Studio Torta;
  • implementing any form of corruption, unlawful favours, and collusive behaviour. Small gifts or customary business courtesies of modest value (i.e. of a total value of less than 100 Euro/year) are an exception to the above.

Article 9 – Duty of confidentiality

The Shareholders, Employees and Contract Workers of Studio Torta are obligated to absolute confidentiality on all the facts and documents of which they come to know in carrying out their work, with reference both to Clients and to Studio Torta. In addition to the areas established by law, professional secrecy includes the internal organization of Studio Torta, internal regulations, projects, ideas and discussions, also with reference to events and situations that are no longer current. The information, knowledge and data acquired or processed during one’s work or through one’s duties belong to Studio Torta and cannot be used, communicated or disclosed without the specific authorization of the relative manager, both during the employment relationship and at its end.

Article 10 – Duty of business propriety

In carrying out the professional activity, the Shareholders, Employees and Contract Workers of Studio Torta, must avoid directing the choices of Clients toward solutions that are not adequate to the culture, to the quality standard, or to the objective needs of the Clients. The activity must always be aimed at the satisfaction of the customer, without getting engaged in consultancy and services without the reasonable certainty of being able to operate with a quality standard to meet Client expectations and standards.

Article 11 – Duty of impartiality

Any disputes that may arise within Studio Torta, whether due to personal problems or concerning situations between offices and different functions, must be immediately represented with calmness and objectivity to the hierarchical superior function, which will resolve the dispute taking into account the proper nature of the problem, in order to better carry out operations and in the interest of Clients and Studio Torta.

Article 12 – Harassment at the workplace

Studio Torta is committed to creating a serene working environment within it, where everyone can work in observance of the laws, principles and shared ethical values. Shareholders, Employees and Contract Workers of Studio Torta have the right to work in an environment free from discrimination of race, religion, sex, ethnic belonging, trade union membership or politics or of any other nature. Internal and external working relations must be as fair as possible and must not give rise to any harassment, meaning as such:

  • intimidation, humiliation, threats or other behaviour likely to isolate or harm the psycho-physical well-being of individuals or groups;
  • undue interference in other people’s work performance;
  • hindrance to the prospects of employment of others for reasons of personal competitiveness;
  • subordinazione di attività e comportamenti di rilevanza per la vita lavorativa del destinatario all’accettazione di favori sessuali;
  • any act or unwanted behaviour, also verbal, with a sexual connotation bearing offence to the dignity and freedom of the person enduring it.

Article 13 – Behaviour in Social life

In every circumstance of Social life, and also outside business hours and workplaces, the Shareholders, Employees and Contract Workers of Studio Torta must behave in a way that brings Honour to their Profession. In business hours and at the workplace, behaviour must be inspired by fairness toward Colleagues, respect and a spirit of cooperation. In private relationships, any abuse of the position held that could bring undue benefits to oneself or to others is absolutely prohibited.

Article 14 – Client relations

It should be adequately explained to Clients how each activity is carried out, its consequences, its risks, if any, and its expected costs to enable Clients to have sufficient information to make informed decisions. Written communications, both periodic and occasional, must be clear, complete and easy to understand. Requests for information and clarification from Clients, both written and verbal, must be handled with competence, clarity and timeliness. Relations with Clients must be geared to loyalty, transparency and confidentiality, and characterized by courtesy and professionalism in order to consolidate the relationship of trust with the Clients and to promote the image of Studio Torta among the general public. Staff, within the scope of their expertise, must always be informed and up-to-date in order to give Clients satisfactory answers and to facilitate informed choices.

Article 15 – Supplier relations

Studio Torta gears Supplier relations to principles of integrity, honesty, fairness, mutual respect and non-discrimination, encouraging continual cooperation and solid, transparent, and lasting relationships. Supplier selection and the determination of the conditions of purchase are based on an objective assessment of the quality and price of the goods or services, as well as guarantees of assistance and timeliness.

Article 16 – Relations with Public Institutions

Studio Torta, in the course of its professional assignments, relates to public, national, community and international institutions in full respect of the existing legislative provisions and with an attitude of the utmost correctness, cooperation and transparency.

Article 17 – Relations with Professional Associations

Studio Torta participates with expertise, proactivity and transparency in the life of the Professional Associations of reference both to improve and simplify the execution of its professional activities and to enhance its professional activities with Clients and with Public Institutions.

Article 18 – Professional training

The quality of human resources constitutes a wealth of fundamental importance for the business and the professional work of Studio Torta. Studio Torta enhances the professionalism of Shareholders, Employees and Contract Workers, by supporting their training and providing them with training tools to develop and grow their specific skills.

Article 19 – Use of company assets

The use of company assets is strictly functional to the performance of the activities of Studio Torta. The Shareholders, Employees and Contract Workers of Studio Torta must use the company’s assets and equipment with care and diligence, avoiding any behaviour that could cause harm, compromise their operation or be harmful to Studio Torta. It is absolutely forbidden to use any kind of property of Studio Torta for personal purposes and it is absolutely forbidden to take away documents of any kind and to use them for one’s own purposes. Personal computers, communication instruments and other computer equipment and related software are work tools and therefore must be properly stored and can only be used for professional purposes in relation to the tasks assigned and not for personal purposes; in addition, their theft, damage or loss must be promptly reported to Studio Torta. It is not allowed to install software and/or hardware tools that are not permitted by one’s user profile or are the subject of another party’s industrial rights. Any non-professional content or applications may be removed at any time.

Article 20 – Use of the Internet and email

During business hours, it is not allowed to participate, for non-professional reasons, in forums, use chat lines, electronic message boards or register in guest books even with pseudonyms (or nicknames) using the company or one’s own tools. The official Studio Torta email is a work tool and therefore it is not allowed to be used for personal reasons.

Article 21 – Listening and dialogue

Studio Torta believes that listening and dialogue are at the base of relationships that generate trust. For this purpose, Studio Torta actively:

  • promotes internal communication to enable people to participate better and with greater awareness in the life of Studio Torta;
  • directs communication to criteria of correctness, completeness, simplicity and transparency;
  • develops information sharing tools;
  • facilitates the exchange of experiences, which also facilitate the comparison and integration between different areas of activity and departments of Studio Torta;
  • applies best efforts to develop, in those who have responsibilities, a specific sensitivity in understanding the needs of Shareholders, Employees and Contract Workers, as well as to take advantage of their suggestions and differences of opinion, as an opportunity for improvement and growth of Studio Torta.

Article 22 – Cohesion

Cohesion is the hallmark of a community of people who work well together with the pride of being part of a single project. To grow and consolidate, around a strong and shared identity, the spirit of belonging of all Staff, Studio Torta:

  • spreads its values;
  • provides all the information on the strategies and objectives of Studio Torta, with the aim of sharing the elements that characterize its identity;
  • makes the capacity to propose oneself as a leader and reference point grow in those who have responsibilities in order to implement actions that are always consistent with the ethical principles of Studio Torta;
  • implements management and reward policies capable of recognizing and enhancing the individual and group contribution to achieving objectives;
  • provides for forms of economic participation in the successes of Studio Torta;
  • promotes solidarity initiatives to support colleagues in difficulty and for socially relevant purposes.

Article 23 – Initiatives to reconcile work and private commitments

Studio Torta is aware that in order to facilitate reconciliation between work commitments and the private sphere, commitments and actions are needed to simplify active participation in work activities and to responsibly stimulate people’s quality of life. For this purpose Studio Torta undertakes to support, both economically and in any other form possible and identified in agreement, Shareholders, Employees or Contract Workers in the event of personal, family or social difficulties

Article 24 – The Board of Directors

The Board of Directors must manage Studio Torta according to correctness, transparency and legality, pursuing the interest of all Shareholders. The Board of Directors shall refrain from any conduct aimed at unlawfully influencing the voting of Shareholders in the shareholders’ meeting. The Board of Directors must provide, where required, correct, transparent, precise and truthful information to the Auditing Company and the Statutory Auditors, with a view to full cooperation in order to facilitate the auditing and control activities assigned to the Auditing Company.

Article 25 – Health and Safety

Studio Torta guarantees a working environment that protects the health and safety of its staff. Studio Torta spreads and consolidates a culture of safety with a key to prevention, developing risk awareness and promoting responsible behaviour on the part of all. Shareholders, Employees and Contract Workers of Studio Torta undertake to promptly report any shortcomings or non-compliance with the applicable rules on safety at the workplace.

Article 26 – Environmental protection

Studio Torta recognizes the protection of the environment as a primary value and therefore undertakes to promote energy saving, reject waste, implement separate waste management, and implement the correct reuse of recyclable products.

Article 27 – Violation of the provisions of the Code of Ethics

Violation of the provisions of the Code of Ethics may result in the loss of trust between Studio Torta and the person responsible for the violation. Violation of the rules contained in the Code of Ethics may result in the penalties provided for by law and by the employment contract.

Article 28 – Advice and recommendations

In order to allow a complete implementation and application of the Code of Ethics, Studio Torta urges Shareholders, Employees and Contract Workers to promptly transmit any advice and recommendations directly to the Board of Directors.