Art. 1 - SCOPE OF APPLICATION AND RECIPIENTS OF THE CODE OF ETHICS
The principles and provisions of this Ethical Code (hereinafter the “Code”) constitute exemplary specifications of the general obligations of diligence, correctness and loyalty, which qualify the execution of professional and working services and behavior in the workplace, as well as guiding values which must inspire the daily activities of all members of the organization of WE ADVISOR S.r.l. – STP (hereinafter “WE ADVISOR”).
The principles and provisions of the Code are binding for Professional Shareholders, for Directors, for all persons linked by subordinate employment relationships with WE ADVISOR (“Employees”) and for all those who collaborate with WE ADVISOR, whatever the nature of the collaboration relationship (“Collaborators”). Shareholders, Directors, Employees and Collaborators are hereinafter jointly defined as “Recipients”.
The Code is brought to the attention of third parties by publication on the WE ADVISOR website.
Art. 2 - GENERAL PRINCIPLES
The Code constitutes a set of principles whose observance is of fundamental importance for the regular functioning, the reliability of the management and the image of WE ADVISOR. The operations, behaviors and relationships are inspired by these principles, both within the structure of WE ADVISOR and outside them.
The Code is also based on non-juridical norms and is aimed at the moral and professional sensitivity of individuals. All participants in carrying out the activity of WE ADVISOR have the moral responsibility of disseminating and applying the values expressed by the Code, with reference to the functions, duties or tasks assigned to them.
In particular, the guiding values of WE ADVISOR, which must inspire the daily operations of all Recipients, are the following:
- customer satisfaction, intended as the rendering of services that have the maximum correspondence to customers’ needs, status, culture and expectations;
- customization of services, intended as the search for the best and most useful solutions for the customers;
- compliance with the law, intended as the adoption of operating methods suitable to the WE ADVISOR ethics and respectful of all the provisions of the law and of regulations in general;
- correctness of conduct, intended as the adoption of conduct in compliance with the quality standards described in this Code, with the law and with the ethical codes of the relevant professions;
- fair remuneration for the activity carried out by WE ADVISOR, intended as the search for an adequate profitability to the complexity and riskiness of the activities carried out;
- priority of investments to support the activity and constant improvement of Members, Employees and Collaborators, from the human, cultural and professional point of view.
The guiding values have an equal value and must be perceived by third parties as elements that distinguish the operations of WE ADVISOR from other subjects carrying out similar activities.
WE ADVISOR recognizes that human resources are a factor of fundamental importance for its development. The management of human resources is based on respect for the personality and professionalism of each of them within the general framework of this Code.
Art. 3 - LIABILITY
Each Recipient carries out his work and performance with diligence, efficiency and fairness, making the best use of the tools and time at his disposal and assuming the responsibilities related to the functions, duties and / or tasks entrusted to him/her.
Art. 4 - IMPARTIALITY AND NON-DISCRIMINATION
The Recipients, in fulfilling the work and / or professional performance, ensure equal treatment to all subjects who for various reasons have relations with WE ADVISOR, avoiding any type of discrimination based on age, sex, sexual orientation , the state of health, race, nationality, political opinions and religious beliefs of the interlocutor.
Art. 5 - CORRECTNESS
All the actions and operations carried out and the behaviors held by each of the Recipients in the performance of their functions, tasks or assignments are inspired by correctness, legitimacy under the formal and substantive aspect and the protection of WE ADVISOR, according to the internal procedures and the regulations in force in the countries in which it operates.
The Recipients do not use for personal purposes information, goods and equipment at their disposal in carrying out their functions, tasks or assignments.
Each Recipient does not accept, nor make, for himself or for others, pressure, recommendations or reports, which could harm WE ADVISOR or undue advantages for himself, for WE ADVISOR or for third parties; each Recipient also rejects and does not make undue offers of money or other benefits.
Recipients of the Code are prohibited from accepting gifts or other benefits from subjects in any way interested in the activity of WE ADVISOR. Exceptions are small gifts or courtesies of modest value for commercial use (gifts for advertising or holidays, invitations to conferences, convivial meetings, etc.).
Art. 6 - CONFIDENTIALITY
The Recipients ensure the utmost confidentiality regarding news and information of the stakeholders with whom they come into contact, in compliance with the provisions of the law, the regulations in force, the ethical codes and internal procedures.
The Recipients respect professional secrecy and keep confidential news and information learned in the exercise of their functions, duties or assignments, even after the termination of the employment or professional relationship.
Each Recipient is required to:
- acquire and process only adequate, pertinent and limited data to what is necessary for the purposes of the duties performed or the assignment received and in direct connection with his functions;
- acquire and process the data only within specific procedures, in compliance with the principles of lawfulness, correctness and transparency;
- keep the data in such a way that it is prevented that others, unauthorized, become aware of it and, in any case, to guarantee adequate security of the data;
- associate the data in such a way that any person authorized to have access to it can easily draw a framework, as precise, exhaustive, exact and up-to-date as possible;
- store and process the data for a period of time not exceeding the achievement of the purposes for which they are processed;
- do not communicate to third parties or disclose to the media the data or other news related to the performance of the activities carried out within WE ADVISOR, except for specific authorizations.
Art. 7 - CONFLICT OF INTEREST
The Recipients pursue, in carrying out the collaboration, the objectives and general interests of WE ADVISOR and its customers.
The Recipients must inform without delay, taking into account the circumstances, their contact persons of the situations or activities in which they could be holders of interests in conflict with those of WE ADVISOR or of the customers (or if these interests are joint immediate holders), and in any other case in which relevant reasons of convenience occur. The Recipients respect the decisions made by WE ADVISOR in this regard.
Art. 8 - ACCOUNTING TRANSPARENCY AND COMPLETENESS OF THE TRANSACTION
Accounting transparency is based on the truth, accuracy and completeness of the basic information for accounting records.
All actions and operations of WE ADVISOR must have adequate registration and it must be possible to verify the decision, authorization and execution process.
Adequate supporting documentation for the activity carried out is kept on file for each operation, in order to be able to carry out checks at any time that certify the characteristics and reasons for the operation and identify the persons who authorized, carried out, registered and verified the operation itself.
The Recipients are required to provide complete, transparent, understandable and accurate information, so that in setting up relations with WE ADVISOR, the stakeholders are able to make autonomous and aware decisions of the interests involved, of the alternatives and of the relevant consequences.
Art. 9 - POLICY TOWARDS STAFF
WE ADVISOR is committed to creating a serene working environment within it, in which everyone can work in compliance with the laws, principles and shared ethical values.
WE ADVISOR enhances the professionalism of Employees and Collaborators, supporting their training, making training tools available to them, trying to develop and increase specific skills.
WE ADVISOR strongly rejects any discriminatory treatment or behavior towards its staff.
WE ADVISOR also undertakes to comply with the legislation on safety at work and to promote safety in all the places which are part of the work environment itself.
Art. 10 - RELATIONS BETWEEN EMPLOYEES - COLLABORATORS - SHAREHOLDERS
Relations between Shareholders, Employees and Collaborators must always be based on the principles of a civil coexistence and must be carried out in mutual respect for the rights and freedom of persons.
Art. 11 - RELATIONS WITH EXTERNAL SUBJECTS, RELATIONS WITH THE PUBLIC ADMINISTRATION, RELATIONS WITH POLITICAL ORGANIZATIONS AND TRADE UNIONS
Recipients must comply with the rules of this Code also in relations with the outside world. Relations with public institutions regarding WE ADVISOR will be held only by persons authorized to do so.
All relations with the Public Administration must be aligned with the principles of diligence, transparency and honesty.
The Recipients of this Code must behave in a manner inspired by the utmost correctness and integrity in relations with employees and representatives of public bodies, law enforcement agencies, political forces and trade unions.
Gifts and acts of courtesy and hospitality to representatives of governments, public officials and public employees are permitted only when they are of modest value and in any case such as not to compromise the integrity or reputation of each of the parties and cannot be interpreted as finalized to acquire advantages in an improper way.
Art. 12 - RELATIONS WITH THE JUDICIAL AUTHORITY
WE ADVISOR, in carrying out its business, operates in a lawful and correct manner by collaborating with the Judicial Authority, the Police Forces and any Public Officials who has inspection powers and carries out authorized investigations against WE ADVISOR customers / potential customers, in compliance of professional secrecy.
WE ADVISOR requires that all Shareholders, Employees and Collaborators give the maximum availability and collaboration towards anyone called to carry out inspections and checks on behalf of the Public Security Authoritis, INPS, the Guardia di Finanza, the Public Prosecutor’s Office, and any other Public Administration.
No one should try to persuade others to provide false or misleading information to the relevant authorities.
Art. 13 - RELATIONS WITH CUSTOMERS
Relationships with customers must be based on loyalty, transparency and confidentiality and characterized by courtesy and professionalism, and this is to consolidate the relationship of trust with customers and promote the image of WE ADVISOR among the public.
Shareholders, Employees and Collaborators, within the scope of their skills, must always keep themselves informed and updated to offer customers satisfactory answers and encourage informed choices.
With this in mind, it is the Recipients’ responsibility to provide information as clear, complete and comprehensible as possible to the interlocutor.
Art. 14 - RELATIONS WITH SUPPLIERS
The selection of suppliers and the determination of the purchase conditions are based on an objective assessment of the quality and price of the good or service, as well as guarantees of assistance and timeliness.
Art. 15 - PENALTY PROVISIONS
The provisions of this Code are an integral part of the contractual obligations assumed by the Recipients, or by subjects having business relations with WE ADVISOR.
Violation of the rules of the Code may constitute non-fulfillment of contractual obligations, with all legal consequences, also in relation to the termination of the contract/relationship or the assignment and any compensation for damages.