Code of Ethics

TITLE I
INTRODUCTION

Article 1. – Recitals
This Code sets forth the commitments and the ethical responsibilities for the conduction of business and legal activities undertaken by Gatti Pavesi Bianchi Studio Legale Associato (hereinafter “GPB” or “the Law Firm”), its Associates, employees and collaborators.
GBP affirms that it carries out its internal and external activities in accordance with the principles set forth in this Code, in the belief that it is important for the Law Firm’s success.
Article 2. – Mission statement
GPB’s mission is to efficiently provide high quality legal services to the market, in order to develop and enhance the professional value of the Associates, to satisfy the clients’ needs and to endorse all the people working here.
Article 3. – Aims and Values
In the achievement of such mission statement, GPB inextricably adheres to the following principles of conduct:
a. to condemn and reject any unlawful or dishonest behaviour (with regards to the community, public authorities, clients, workers, investors and competitors) in the achievement of its economic aims, which are accomplished solely through the performance of high quality and effective services, based on experience, customer focus and innovation;
b. to provide organizational measures in order to prevent any violation of the principles of lawfulness, transparency, correctness and  honesty by its employees and collaborators and to monitor their compliance and correct implementation;
c. to undertake to promote fair competition, which is necessary to its interest as well as the interest of all of the other market players, clients and stakeholders in general;
d. to pursue excellence and market competitiveness, offering its clients high quality services which effectively meet their needs;
e. to safeguard and endorse its human resources;
f. to undertake to use its resources responsibly, with a view of achieving sustainable development and respecting the environment and the rights of future generations.
TITLE II
PRINCIPLES OF CONDUCT IN CLIENT RELATIONS
Article 4. – Listening, dialogue, transparency
GPB believes that clients should always be the centre of its attention and that only a continuous dialogue will permit it to understand their actual expectations and to maintain a high level of excellence.
In particular, through dialogue with its clients, the Law Firm is able to accurately identify their real needs, a fundamental starting point for offering advice and assistance in accordance with such needs, in the knowledge that it plays a key role in providing legal assistance.
The Law Firm believes that the basis of a lasting relationship is trust and communication which allows the client to be in a position to understand the nature and the value of all of the services offered. GPB also believes that our services must be accessible to all and therefore:
a. not to discriminate clients on the basis of their nationality, religion or gender;
b. to formulate its offer so that all of the social classes can find a response to their needs;
c. to operate in order to apply a pricing policy which is in line with the services offered;
d. to undertake to make all of the Law Firm’s offices accessible for disabled people, removing any architectural barriers.
Article 5. – Conflict of interest
In compliance with the Code of Conduct for Italian Lawyers, the Law Firm ensures full compliance with the rules designed to prevent conflicts of interest, and in particular Article 37 of such Code:
“A lawyer shall refrain from accepting any employment that may create a conflict with the interests of a client or which may interfere in the execution of any other employment, even if not a professional one.
I. A conflict of interest arises if the acceptance of a new client may result in a violation of confidentiality applicable to information supplied by another client, if the knowledge which the lawyer has about an existing client’s business may provide an unfair advantage to the new client, or if the representation of an existing client limits the lawyer’s independence in carrying out the new representation.
II. The obligation to refuse an employment must be respected also if the opposing parties of a controversy revert to different lawyers who are member of the same law firm or professional association”.
Such aim is also achieved through the use of management software which has been specially developed for the Law Firm.
TITLE III
PRINCIPLES OF CONDUCT IN RELATIONS WITH EMPLOYEES AND COLLABORATORS
Article 6. – Respect for people
GPB believes that respect for the personality and dignity of each employee and collaborator is the basis for the development of a work environment permeated by mutual trust, loyalty and enriched by the contribution of each person:
a. by adopting recruitment and management of employees and collaborators that are based on fair and consistent behaviour, preventing favouritism, abuse and discrimination on the basis of gender, ethnicity, religion, political and trade union affiliation, language, age or disability;
b. by ensuring equal development and professional growth opportunities, providing access to training and professional updating initiatives and by allocating roles;
c. by allowing all employees and collaborators the opportunity to express their individuality and professional creativity, valuing the diversity and the individuality of each person, as an innovative drive and essential contribution to the growth of the Law Firm;
d. by taking the utmost care in setting goals, fostering understanding and sharing, in order to promote correct and transparent conduct in the relationships with clients;
e. by establishing objective and transparent incentive systems, providing for realistic attainable goals;
f. by promoting policies that facilitate the balance between personal and professional life, favouring forms of flexibility and carrying out initiatives for the reconciliation of professional and private commitments by recognising that a person’s private life is fundamental.
Article 7. – Initiatives to reconcile professional and private commitments
GPB understands that in order to render it easier to reconcile professional and private life, commitments and actions must be implemented.
To this end GPB undertakes to:
a. facilitate pregnancy, maternity and parental care, through providing economic support for both employees and collaborators, providing the latter group with a paid leave of absence up to a maximum of six months and a further six months unpaid leave of absence which is consistent with employment needs;
b. implement, in accordance with applicable regulations, if permitted, initiatives aimed at developing forms of internal “social enterprise school” and “mini club” to facilitate working mothers devoting the necessary attention to their young children;
c. encourage participation in partnership volunteer programme initiatives, such as for a paid period of one week each year to participate in volunteer activities without having to use days of holiday, leave of absences or vacations;
d. allow, if compatible with employment needs, a sabbatical of up to six months which can be used no more than once every five years, for research, study, volunteer work or other activity deserving of protection;
e. support, both economically and in every other possible and agreed identifiable way, the employee or the collaborator experiencing personal, family or social difficulties, including legal issues and health.
Article 8. – Listening and dialogue
GPB believes that listening and dialogue are the foundation of relationships that generate trust. To this end it:
a. promotes the strategic role of internal communication to enable people to participate with more awareness in the Law Firm’s activities;
b. bases communication on correctness, completeness, simplicity and transparency criteria;
c. develops tools for sharing of information and the exchange of experiences, which will also facilitate the comparison and integration among the different business areas and departments of the Law Firm;
d. operates to develop in those who hold special offices, a specific sensitivity in understanding the needs of employees and collaborators, as well as to value their suggestions and differences of opinion as opportunities for improvement and growth of the Law Firm.
Article 9. – Cohesion
Cohesion is the distinctive element of a community of people who work well together and are proud to be part of a single project.
In order to grow and strengthen itself, around a strong and shared sense of belonging of all its employees and collaborators, the Law Firm:
a. explains and spreads its values, constantly checking that they are implemented in such a way so that everyone can identify with such values;
b. makes available all the information on the Law Firm’s strategies and objectives, with the purpose of sharing the elements that characterise their identity;
c.  develops the ability of those holding positions of responsibility to act as a guide and point of reference to adopt actions which are always consistent with the ethical principles of the Law Firm;
d. adopts management and bonus which recognise and value the contribution of individuals and groups in order to achieve its goals;
e. provides for partnerships schemes, also on an economic basis, to share in the successes of the Law Firm;
f. promotes initiatives of solidarity to support colleagues in difficulty and to pursue socially significant goals.
Article 10. – Duties of employees and collaborators
Employees and collaborators must act honestly in order to comply with the obligations stipulated in the employment contract and the provisions of the code of ethics, ensuring the required services.
Employees and employees should know and implement the provisions of the firm policies on information security to ensure its completeness, confidentiality and availability. It is required to draft its documents using clear, objective and comprehensive language, and allowing any checks performed by colleagues, managers or authorised external parties.
All employees and contractors are required to avoid situations which may give rise to conflicts of interests and refrain from having any personal benefit in business opportunities of which they become aware during the performance of their functions.
By way of example the following situations can give rise to conflicts of interests:
a. having economic interests with suppliers, clients or competitors (ownership of shares, professional appointments, etc.) even through their families;
b. liaising with suppliers and working for suppliers, even through a family connection;
c. accepting money or favours from people or enterprises that have or intend to enter into business relations with the Law Firm.
In the event that even only the appearance of a conflict of interests occurs, the employee or collaborator shall immediately notify the person responsible, which evaluates the matter on a case by case basis. The employee or collaborator s also required to provide information about activities conducted outside of working hours, in case they may appear to be a conflict of interest with the Law Firm.
Each employee or collaborator is required to work diligently to protect the Law Firm’s assets by acting responsibly and in line with the established operating procedures to regulate their use. In particular, each employee must:
a. use with care and prudence the assets entrusted to them;
b. avoid improper use of firm assets that may cause damage or reduce efficiency, or otherwise be contrary to the interest of the Law Firm.
GPB reserves the right to prevent the incorrect use of its assets and infrastructure through the use of accounting, reporting, financial control and analysis and risk prevention, while complying with the provisions of the applicable law (the privacy law, workers’ statutes, etc.).
With regard with information technology applications, each person must:
a.  scrupulously comply with the provisions of the firm security policies (see the document “ICT and Security Policy”), in order not to compromise the functionality and protection of information systems;
b. not send e-mail messages that are threatening or insulting or to resort to a low-level language, or make inappropriate comments that could offend the person and / or damage to the image of the Law Firm;
c. not surf websites with indecent and offensive content.
TITLE IV
PRINCIPLES OF CONDUCT IN RELATIONS WITH SUPPLIERS
Article 11. – Choice of supplier
Procurement processes are based on the search for maximum competitive advantage for GPB and the granting of equal opportunities to all suppliers; such processes are also based on pre-contractual and contractual behaviour in view of an indispensable and mutual loyal relationship, characterized by transparency and collaboration.
In particular, employees and collaborators of GPB involved in such processes must:
a. not preclude anyone with the necessary requirements from being able to compete for the signing of contracts, adopting objective and documented criteria in the shortlist;
b. ensure sufficient competition in tenders; for example by considering at least three companies in the selection of the supplier; any exceptions must be authorized and documented.
c. In any case, if the supplier, in carrying out its activities, adopts conduct not in line with the general principles of this code, GPB is entitled to take appropriate measures to preclude any further collaboration.
Article 12. – Integrity and independence in relations
Relations with suppliers are governed by common principles and are subject to constant monitoring by GPB. These relations include financial and consultancy agreements.
The entering into a contract with a supplier must always be based on extremely clear relationships, avoiding all forms of dependency. Thus, by way of example:
a. any contract with an estimated value of more than 50% of the turnover of the supplier must be communicated to GPB in accordance with the established procedures;
b. projects with long-term binding periods with short-term contracts that require continuous renewals with price reviews are usually avoided, or consultancy agreements contracts without an adequate transfer of know-how, etc., are generally avoided;
c. it is not fair to induce a supplier to enter into an unfavourable contract on the basis of leading him to understand that a subsequent more advantageous contract may be signed.
Article 13. – Gifts, presents and benefits
No gift is permitted that could even be interpreted as exceeding normal business or courtesy practices, or which is aimed at obtaining favourable treatment in the conduct of any activity relating to GPB. In particular, any type of gift to Italian or foreign public officials or their family members which might influence their independent judgment or induce them to grant any benefit is prohibited,
This rule concerns both gifts which are promised or offered and received; it should be noted that a gift is any type of benefit (free attendance at conferences, promise of a job offer, etc.).
Any free gifts of GPB are intended to promote the brand image of the Law Firm.
The partners, employees or collaborators of the Law Firm who receive gifts or benefits which no dot fall under those permitted, are required, according to established procedures, to notify the person responsible in the Law Firm which will assess the appropriateness of such gift or benefit and will inform the sender of the relevant policy of GPB.
TITLE V
PRINCIPLES OF CONDUCT IN RELATIONS WITH SOCIETY
Article 14. – Environmental Policy
Environmental protection is one of the key aspects of the Law Firm’s commitment. (see also in this regard the document titled “Environmental Policy”).
One of the principles of social responsibility policy is the refusal to waste resources and the attention to the environmental consequences of our choices. GPB believes that it can exert a significant impact in terms of environmental sustainability, particularly in the social and environmental context in which it carries operates, both in the short-term and in the long-term. This impact is due to the consumption of resources and the generation of emissions and waste directly related to business activities (direct impact) as well as activities and behaviour that does not directly control clients and suppliers, as they are put in place by third parties with whom the Law Firm deals (indirect impact).
In this way, the Law Firm ensures full and substantial compliance with environmental regulations and continually seeks innovative and effective solutions in the environmental field, including through the offer of specific products and services to its employees and by offering solutions to its suppliers.
Article 15. – Responsible and efficient use of resources
GPB pursues conscientious consumption of the resources needed to conduct its business, including through the implementation of an environmental management system and by improving the energy efficiency of its activities.
The Law Firm, also by monitoring environmental data and people awareness, strives to continuously improve its environmental behaviour.
Article 16 – Environmental and social responsibility along the supply chain
The Law Firm recognizes that it has a responsibility towards the environment and society which extends along the entire supply chain and is therefore concerned with implementing policies with suppliers for environmental protection and respect for human rights and workers’ rights, respecting suppliers who base their activities on the environmental and social sustainability and who adopt the necessary measures and means to minimise the negative impacts caused by their activities.
Article 17. – Support of the non-profit sector
The Law Firm recognises the role of the non-profit sector for the development of a fair and cohesive society. To this end the Law Firm:
a. supports non-profit and social enterprises by developing partnerships for the implementation of projects that benefit the community;
b. promotes the establishment of networks of social enterprises for the implementation of initiatives in favour of disadvantaged groups;
c. contributes to the creation or participation in non-profit organizations – such as Foundations and Consortiums – whose corporate purpose is social needs and community service;
Article 18. – Support to communities through contributions and sponsorships
The Law Firm identifies the material and immaterial needs and requirements of the community and supports them also through liberal donations and sponsorships:
a. in the selection of the relevant sectors GPB pays special attention to whether they are consistent with its values, the type of initiatives proposed and the importance of the social needs they intent to meet – including the enhancement and protection of the historical, artistic and cultural projects;
b. operates in a transparent and accountable way and through mechanisms to avoid any possible conflict of interests of a personal nature of in relation to the Law Firm;
c. makes liberal donations irrespective of the commercial interests pursued.
Article 19. – Relationships with institutions
The Law Firm’s relationships with the State institutions and their various agencies and with international organizations are aimed exclusively at forms of communication for assessing the implications of legislative and administrative activities of the Law Firm and its clients. They are also necessary for responding to informal requests and inspections by competent authorities (interrogations, interpellations, etc.), or to make known the position of the Law Firm or its clients on significant issues.
TITLE VI
RULES ‘OF IMPLEMENTATION AND CONTROL PROCEDURES
Article 20. – Duties of the committee for internal control in implementing and monitoring the compliance with the code of ethics (Evaluation Committee)
With regard to the code of ethics the committee for the internal control must perform the following duties:
a. to take decisions on important breaches of the code;
b. to express binding opinions on changes to the most relevant policies and procedures in order to ensure consistency with the code of ethics;
c. to continuously update the code of ethics..
In the event that the Evaluation Committee is not established, such duties will be performed by the Executive Committee.
Article 21. – Reports of breaches and non-compliance
For each stakeholder the Law Firm will establish communication channels that can address their reports.
Alternatively, all stakeholders can report, in writing and not anonymously, any breach or suspected breach of the code of ethics to the Ethics Committee that shall analyse the report, possibly listening to the author and the person responsible for the alleged breach.
The reporting of any non-compliance with this Code shall be sent by mail to one of the members of the Evaluation Committee or sent by post to the following address:
Gatti Pavesi Bianchi Studio Legale Associato
Evaluation Committee
Piazza Borromeo 8, 20123 Milan
.
The Evaluation Committee acts in such a way as to protect the informants against any type of retaliation as an act that could give rise even to the suspicion of it being a form of discrimination or retribution (for example, for suppliers: interruption of business relations, for employees: no promotion, etc.). The identity of the informer is to remain confidential, except as required by law.
Article 22. – Assistance in the event of breaches and non-compliance
In view of any non-compliance of Code, the Law Firm will adopt the consequent measures, inspired – when it does not give rise to fraudulent conduct or acts which breach specific legal provisions, contracts or regulations – by constructive approach, including through the provision of training programmes, to reinforce the awareness and attention of individuals’ compliance with the values and the principles enshrined in the Code.

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