Ethical Code

1. Introduction

1.1 Purpose of the document

All activities of Omega3C must be carried out in compliance with the law, within a framework of fair competition with honesty, integrity, fairness, and good faith, while respecting the legitimate interests of customers, employees, business, and financial partners. 

The following information, available on the home page of the websites and (hereinafter the "Website"), is provided by OMEGA3C S.R.L., in its capacity as the data controller (hereinafter "Omega" or the "Controller"), to visitors of the Website who wish to submit a request through the Website's contact form to inquire about the services offered. Omega ensures that the data will be processed in compliance with applicable regulations.

Everyone working at Omega3C, without distinction or exception, is committed to observing and ensuring compliance with these principles within the scope of their functions and responsibilities.
Under no circumstances can the belief that one is acting in the best interest of Omega3C justify behaviour contrary to these principles.
Omega3C clearly defines the set of values it recognises, accepts, and shares, as well as the set of responsibilities it takes on internally and externally. For this reason, the "Ethical Code" or "Code" has been prepared, which encompasses a set of principles and rules compliance with which by recipients is of fundamental importance for the proper functioning, reliability, and reputation of Omega3C.
The Ethical Code aims to establish fairness, equity, integrity, loyalty, and professional rigour in all operations, behaviour, and ways of working, both in internal relationships within Omega3C and in relationships with external parties, with a focus on respecting the laws and regulations of the countries where Omega3C operates, as well as adhering to the company's procedures. 

2. General Principles

2.1 Recipients

The individuals to whom the provisions of this Ethical Code apply are referred to as "Recipients." This includes directors, all employees of Omega3C companies, and anyone who, directly or indirectly, permanently, or temporarily, establishes dealings or relationships with Omega3C or, in any case, acts to pursue its objectives.
Omega3C's business is based on the principles of fairness and transparency.
It is primarily the responsibility of managers to embody the values and principles outlined in the Code, being accountable towards both internal and external stakeholders and fostering trust, cohesion, and the spirit of Omega3C.
Employees of Omega3C, while already complying with the law and applicable regulations, are expected to align their actions and behaviour with the principles, objectives, and commitments set forth in the Code.
The Directors, in setting corporate objectives, are guided by the principles contained in the Code.
All actions, operations, negotiations, and behaviour adopted or carried out by Omega3C employees in the course of their work are guided by the utmost integrity in the management, completeness and transparency of information, formal and substantive legitimacy, and clarity and truthfulness in accounting records, in accordance with applicable regulations and internal procedures.
Each employee must contribute professionally according to their assigned responsibilities and act in a manner that protects the prestige and image of Omega3C.
Each Recipient is required to be familiar with the Ethical and Conduct Code, actively contribute to its implementation, and report any deficiencies to the relevant department.
To ensure full compliance with the Ethical and Conduct Code, each employee who becomes aware of situations that effectively or potentially constitute a significant violation of the Code must promptly report them to their immediate supervisor or the Directors. 

2.2 Commitments of Omega3C

Omega3C ensures:
1. The dissemination of the Code among Recipients;

2. The updating of the Code to align it to evolving societal standards and relevant regulations;

3. The conduct of investigations into any reports of Code violations;

4. The evaluation of facts and subsequent implementation of appropriate punitive measures in cases of confirmed violations;

5. That no one shall face retaliation of any kind for reporting possible violations of the Code or relevant regulations. 

2.3 Obligations for all employees

Every employee is requested to be familiar with the provisions of the Code and the relevant regulations which govern the work undertaken in the context of their work responsibilities.
Every employee is expected to:
1. Refrain from engaging in behaviour contrary to these rules;

2. Seek clarification from superiors or the Human Resources department regarding the application of these rules when necessary;

3. Promptly report to their superior or the Human Resources department any first-hand or reported information regarding possible violations, as well as any requests to violate them;

4. In cases of alleged serious violations, employees are obligated to directly address the report to the Directors, following the procedures outlined in the Procedure for the Management of Reports and Complaints regarding violations of principles and regulations defined and/or recognised by Omega3C.

2.4 Additional obligations for Managers

Each Manager is obliged to:
1. Lead by example and guide employees to adhere to the Code and relevant procedures;

2. Ensure that employees understand that compliance with the Code, as well as procedures and safety regulations, is an essential part of their job performance;

3. Carefully select internal and external collaborators, within their competence, to prevent assignments from being entrusted to individuals who do not fully commit to observing the Code and procedures;

4. Take immediate corrective measures when required by the situation. 

2.5 Applicability of the Code to Third Parties

All Omega3C employees, within the scope of their responsibilities and in dealings with external subjects and discussions with third parties, must:
1. Adequately inform third parties about the commitments and obligations imposed by the Code;

2. Demand compliance with obligations directly related to their activities;

3. Take appropriate internal and, if within their competence, external actions in the event of non-compliance by third parties with the obligation to comply with the Code's rules. 

2.6 Contractual Value of the Code

The Code is an integral part of the employment relationship.
Compliance with the Code's rules must be considered an essential part of the obligations of Omega3C employees.
Violations of the Code's rules may constitute a breach of primary employment obligations or disciplinary misconduct, with all legal consequences, also regarding maintaining the employment relationship and may entail actions for compensation for damages caused by such violations.
For non-employee Recipients, adherence to the Code is an essential prerequisite for the continuation of the existing professional/collaborative relationship with Omega3C. 

3. Behaviour in Business Management

3.1 General Business Management

Omega3C is guided by the principles of loyalty, fairness, transparency, efficiency, and openness to the market in its business relationships.
Omega3C employees and external collaborators acting on behalf of Omega3C are required to demonstrate ethical behaviour and respect for laws in business dealings, emphasising transparency, clarity, fairness, and efficiency. This applies to both business relationships concerning Omega3C's interests and interactions with the Public Administration.
In commercial or promotional relationships, recipients are also obligated to align their behaviour with Omega3C's corporate policies. However, such alignment must never result in actions contrary to the law, current regulations, or company procedures related to specific functions, even if they serve the purpose of pursuing the company's objectives. 

3.2 Gifts and Other Benefits

When dealing with customers, suppliers, and third parties in general, offering money, gifts, or personal benefits with the aim of obtaining undue advantages, whether real or perceived, of any nature (e.g., promises of financial benefits, favours, recommendations, promises of job offers, etc.) is strictly prohibited.
However, acts of commercial courtesy are allowed as long as they are of modest value and do not compromise the integrity and reputation of the recipient or influence their independent judgment.
If a recipient receives gifts beyond the limits of normal courtesy and of significant value, they must refuse them and immediately inform their superior or the Directors. 

3.3 Conflict of Interest

Recipients must avoid situations and/or activities that may lead to conflicts of interest with those of Omega3C or interfere with their ability to make impartial decisions in the best interest of the company.
If a recipient finds themselves in a possible conflict of interest with Omega3C's interests, they must immediately communicate it to their superior or the Directors and refrain from any activity related to the situation causing conflict.
In relationships between Omega3C and third parties, recipients must act according to ethical and legal standards, explicitly prohibiting the use of unlawful favouritism, collusive practices, corruption, or solicitation of personal benefits for themselves or others. Recipients are obligated to promptly report any information that may suggest or imply a potential conflict of interest with Omega3C to their superior and/or the Directors.
Examples of situations that may result in conflicts of interest include, but are not limited to:
1. Having economic and financial interests, including through family members, with customers, suppliers, or competitors;

2. Engaging in employment, also by family members, with customers, suppliers, or competitors;

3. Accepting money, gifts, or favours of any nature from individuals, companies, or entities that are or intend to enter business relationships with Omega3C;

4. Using their position within the company or information acquired in their work in a way that may create a conflict between their personal interests and those of the company. 

3.4 Customer Relationships

Omega3C achieves success by offering high-quality products and services under competitive conditions while adhering to regulations protecting fair competition. Within customer relationships and in compliance with internal procedures, each recipient must strive to maximise customer satisfaction by providing, among other things, comprehensive and accurate information about the products and services offered, thus facilitating informed choices. 

3.5 Proper Use of Company Assets

Every recipient is responsible for safeguarding the resources entrusted to them and has a duty to promptly inform the appropriate departments of any threats or harmful events that may affect Omega3C.
In particular, each recipient must:
1. Operate diligently to safeguard company assets by acting responsibly and in accordance with the established operational procedures regulating their use;

2. Avoid improper use of company assets that could cause damage, reduced efficiency, or be contrary to the company's interests;

3. Obtain necessary authorizations if there is a need to use company assets outside the company's premises. The increasing reliance on information technology requires ensuring the availability, security, integrity, and maximum efficiency of this category of assets.

Each recipient is required to:
1. Refrain from sending derogatory or offensive emails, using inappropriate language, or making inappropriate or unwanted comments that could offend individuals and/or harm the company's reputation;

2. Avoid spamming or engaging in activities such as chain letters that generate a flow of data/information/processes within the company's network such as to significantly reduce network efficiency and negatively impacting productivity;

3. Avoid browsing websites with indecent and offensive content;
4. Take all necessary precautions to protect the functionality and security of personal and company-owned information systems;
5. Avoid installing borrowed or unauthorised software on company systems and never make unauthorised copies of licensed programs for personal, company, or third-party use.
Omega3C specifically prohibits any use of information systems that may violate applicable laws or infringe upon the freedom, integrity, and dignity of individuals, especially minors.
Omega3C also prohibits any use of information systems that may cause undue intrusion or damage to other computer systems.
Even unintentional use of these assets for purposes unrelated to business activities can result in serious damage (financial, reputational, competitiveness, etc.) to Omega3C. Moreover, improper use may lead to potential criminal and administrative sanctions for any misconduct, as well as disciplinary measures against the recipients.

4. External Relations

4.1 Relations with Political Parties, Trade Unions, and Associations

Omega3C does not provide direct or indirect contributions to political parties in Italy or abroad, nor to their representatives or candidates. Every employee must acknowledge that any involvement in political activities occurs on a personal basis, during their free time, at their own expense, and in compliance with applicable laws.
Furthermore, Omega3C does not provide contributions to organisations where a conflict of interest may arise, such as trade unions or consumer or environmental associations.
Cooperation is possible when the purpose is aligned with Omega3C's mission or relates to projects of public interest, when the allocation of resources is clear and documented, and/or when express authorization is granted by the relevant company functions.

4.2 Relations with Public Institutions

Relationships with public entities and organisations necessary for the development of Omega3C's business programs are exclusively reserved for the company's delegated functions.
Relations with public institutions must be characterised by maximum transparency, clarity, fairness, and should not lead to partial, distorted, ambiguous, or misleading interpretations by the relevant public entities with which there are dealings for whatever reason.
Gifts and acts of courtesy and hospitality towards representatives, such as public officials or individuals in public service, are allowed when they are of modest value and cannot be interpreted by a third party as an attempt to gain an advantage improperly.
However, such expenses must be authorised and adequately documented. Specifically, in dealings with public entities for accessing subsidised funds, Omega3C:
1. Rejects any behaviour aimed at obtaining contributions in an improper manner through deception or omission of due information;

2. Prohibits diverting contributions received to purposes other than those for which they were granted. 

5. Personnel Policies

5.1 Human Resource Management

Human resources are essential for the company's existence. The dedication and professionalism of employees are crucial values and conditions for achieving Omega3C's objectives.
Omega3C is committed to developing the skills and competencies of each employee to ensure that individual energy and creativity find full expression in the execution and achievement of the company's mission.
Omega3C provides all employees with equal opportunities for professional growth, ensuring that everyone receives fair treatment based on merit, without any discrimination.
The competent functions must:
1. Apply merit-based, competency-based, and strictly professional criteria for any decision concerning an employee;
2. Select, recruit, train, compensate, and manage employees without any form of discrimination;
3. Create a work environment where personal characteristics do not lead to discrimination.
Each recipient must actively collaborate in maintaining an atmosphere of mutual respect for each person’s dignity and reputation.
Recipients are also required to handle personal data they become aware of during their work in a manner that ensures the confidentiality, image, and dignity of individuals.
Omega3C is committed to promoting and consolidating a culture of safety by raising awareness of risks, encouraging responsible behaviour from all employees, and working to preserve, primarily through preventive actions, the health and safety of workers.
Omega3C's activities must fully comply with current legislation on prevention and protection. Operational management must adhere to advanced criteria for environmental protection and energy efficiency, striving to improve health and safety conditions in the workplace.
Omega3C also guarantees the protection of working conditions by safeguarding the mental and physical integrity of workers, respecting their moral character, and preventing them from being subjected to illicit influences or undue distress. Omega3C therefore opposes any discriminatory or harmful behaviour or attitude that infringes upon a person's beliefs and preferences (such as insults, threats, isolation, excessive intrusion, or professional limitations).
Omega3C strives to ensure that the rights enshrined in the "Universal Declaration of Human Rights" are guaranteed within its activities.
Omega3C rejects the exploitation of child labour.
Omega3C promotes the protection of workers' rights, freedom of association, and trade union rights.
Any violation of the provisions of this article must be immediately reported to the Directors.

5.2 Respect for Colleagues

Omega3C does not tolerate sexual harassment, which includes: subordinating salary prospects or career advancement to the acceptance of sexual favours; making private interpersonal proposals despite explicit or reasonably evident disapproval, which have the potential, given the specific situation, to disturb the recipient's peace of mind.

5.3 Alcohol and Substance Abuse

Omega3C requires that each employee personally contribute to maintaining a work environment that respects the sensitivity of others.
Therefore, the following actions will be considered a conscious taking of the risk of compromising these environmental characteristics during work activities and in the workplace: working under the influence of alcohol or substance abuse; consuming or distributing drugs of any kind during work.

5.4 Transparency of Accounting Information and Internal Controls

All activities and actions carried out by the recipients within their work duties must be verifiable. Accounting transparency is based on the truth, accuracy, completeness, and reliability of documentation related to business events and accounting records.
Each recipient is required to collaborate to ensure that management events are accurately and promptly reflected in the accounting. Adequate supporting documentation for each transaction is kept on record to facilitate accounting entries, identify different levels of responsibility, and accurately reconstruct the operation. Each record must accurately reflect the information contained in the supporting documentation.
Recipients who become aware of omissions, forgeries, alterations, or negligence in the information and supporting documentation are required to report the facts to their superiors or the Directors.

5.5 Internal Controls

Omega3C aims to promote a conscious culture of the importance of an adequate system of internal control at all levels of its organisation. In particular, the internal control system should contribute to achieving company objectives and therefore be focused on improving the effectiveness and efficiency of production and management processes.
All recipients, within the scope of their functions, are responsible for the proper functioning of the internal control system.
Everyone should feel responsible for safeguarding company assets, both tangible and intangible, which are instrumental to the activities carried out.

5.6 Anti-Money Laundering and Counterterrorism

In compliance with applicable regulations, Omega3C takes measures to prevent the use of its economic and financial system for money laundering purposes or the financing of terrorism (or any other criminal activity) by its customers, suppliers, employees, and counterparts with whom it interacts in the course of its activities.
Omega3C diligently verifies available information about business counterparts, suppliers, partners, and consultants to ascertain their credibility and the legitimacy of their activities before establishing business relationships with them.
Omega3C also ensures that its operations, even potentially, do not present the risk of facilitating the receipt, replacement, or use of money or assets derived from criminal activities.

5.7 Adoption, Effectiveness, and Amendments

This Code of Ethics and Conduct is periodically updated, modified, or revised by Omega3C. This Code of Ethics and Conduct was adopted on 1 January 2018.

6. Procedure for Handling Reports and Complaints Regarding Violations of Principles and Rules Defined and/or Recognised by Omega3C

6.1 Object

This procedure covers reports, complaints, and notifications (hereinafter referred to as "reports") regarding cases of alleged fraud, violation of ethical and behavioural principles outlined in the Code of Ethics and Conduct, and irregularities or negligence in accounting practices (hereinafter referred to as "violations").

6.2 Procedural Steps

1. Reports of violations can only be submitted in written form through a signed letter or anonymously by regular mail to Omega3C S.R.L., Corso Magenta 46, 20123 Milan, attention: Directors. However, this procedure encourages both employees and external individuals not to make anonymous reports, as investigating the matter would be difficult without an "identified" source of information.
2. All reports of violations received within the company, regardless of the recipient or source, must be sent to the attention of the Directors.
3. The Directors, with the support of other competent company functions, if deemed necessary, will ensure that all received reports are: Recorded and stored; or Qualified (archived or activated for investigation) with an explanation of the reasons that led to the decision; or Subjected, if deemed necessary, to a verification process with information provided to the parties involved.
4. In order to conduct investigations, the Directors may, at their discretion, involve any company function they deem to have the expertise and/or knowledge to provide them with the necessary support.
5. The Directors may suspend or terminate the investigation at any time if the report is found to be unfounded. If bad faith on the part of the reporter is established, the Directors may initiate proceedings against them.
6. No determination of a violation will be made without first hearing the party involved.

6.3 Whistleblower Protection

In accordance with best corporate practices, the Directors shall not tolerate any form of retaliation by any party against those who in good faith report illegal activities or violations or provide assistance to management in the investigative process. The Directors shall not disclose the identity of the whistleblower and shall not tolerate any initiatives aimed at identifying the whistleblower.