Code Of Ethics

Code of Ethics

adamantia_group_patto_etico

Table of Contents

1. INTRODUCTION

  • 1.1 The Company

  • 1.2 Addressees of the Code

  • 1.3 Availability and Access

2. PRINCIPLES OF THE CODE

  • 2.1 Transparency

  • 2.2 Fairness, Integrity, and Impartiality

  • 2.3 Respect for Individuals and Human Rights

  • 2.4 Respect for Corporate Assets

  • 2.5 Environmental Protection

3. EXTERNAL RELATIONS

  • 3.1 Relations with Clients

  • 3.2 Relations with Suppliers

  • 3.3 Relations with the Public Administration

  • 3.4 Relations with Information Channels and Media

  • 3.5 Relations with Political and Trade Union Organizations

  • 3.6 Gifts, Gratuities, and Hospitality

  • 3.7 Anti-Corruption and Anti-Money Laundering

  • 3.8 Conflict of Interest

4. PERSONNEL POLICY

  • 4.1 Personnel Recruitment and Hiring

  • 4.2 Personnel Management

  • 4.3 Occupational Health and Safety

  • 4.4 Whistleblowing and Reporting of Misconduct

5. ACCOUNTING AND FINANCIAL TRANSPARENCY

  • 5.1 Internal Controls

  • 5.2 Traceability of Operations

6. CONFIDENTIALITY AND DATA PROTECTION

  • 6.1 Information Confidentiality

  • 6.2 Data Protection

7. MONITORING, REPORTING, AND SANCTIONS

  • 7.1 Monitoring the Application of the Code

  • 7.2 Reporting Violations of the Code

  • 7.3 Applicable Sanctions

8. VALIDITY AND UPDATING OF THE CODE

  • 8.1 Entry into Force

  • 8.2 Update Policy

1. Introduction

1.1 The Company

Adamantia Group, hereinafter referred to as the “Company” or the “Group”, is a corporate group consisting of the companies belonging to the business network named Adamantia Group: Adamantia Group Srl, Centro Sistemi Parsec Srl, and EDP Florence Srl. The Group specializes in providing technological solutions within the B2B sector, particularly regarding: ERP management software, business intelligence software, HR management software, cloud solutions, network infrastructures, and hardware.

Through this document, Adamantia Group commits to acting in accordance with the values and principles of transparency, fairness, and ethics toward its internal organization, as well as toward external stakeholders with whom it maintains relations.

This commitment is deemed mutual, requiring all internal and external operators of the Group to observe the values set forth in this Code of Ethics.

1.2 Addressees of the Code

This Code applies, without any distinction, to:

  • Members of the Board of Directors of each of the companies constituting the Group;

  • Executives, employees, and collaborators, both internal and external, of each of the companies constituting the Group;

  • Suppliers, consultants, partners, and any individual or entity operating on behalf of each of the companies constituting the Group.

It is understood that each of the “Addressees” of the Code actively commits to its implementation and to promptly report any instance where a violation is believed to have occurred.

1.3 Availability and Access

This Code is made fully available to each of the Addressees and can be consulted at any time in electronic format at the following URL: www.adamantiagroup.it/codice-etico-adamantia-group

Should technical issues render it inaccessible via the aforementioned web address, it may be requested in writing by contacting the following email address: info@adamantiagroup.com

Any subsequent amendment or update to this Code of Ethics must be published with the correct effective date.

2. Principles Of The Code

2.1 Transparency

Adamantia Group ensures total transparency in the conduct of all corporate activities. This implies that every business operation must be reliable, legitimate, and accompanied by valid documentation demonstrating its truthfulness. To this end, Adamantia Group commits, in full compliance with current regulations, to providing complete and comprehensive accounting and management information.

2.2 Fairness, Integrity, and Impartiality

Fairness, integrity, and impartiality represent fundamental values for Adamantia Group in every business area in which it operates. This includes the social sphere of internal relations with employees and collaborators, as well as external relations with clients and suppliers.

Under no circumstances shall the legitimate interests of Adamantia Group and its Addressees conflict with the aforementioned values, as they are essential and non-negotiable.

Behaviors or actions that promote discrimination, inequality, or favoritism conflict with the requirements of inclusion, collaboration, loyalty, and mutual respect sponsored by Adamantia Group, and will therefore be sanctioned accordingly.

2.3 Respect for Individuals and Human Rights

Adamantia Group commits to protecting the safety and fundamental human rights of all its collaborators and will under no circumstances tolerate behaviors or actions aimed at discriminating against, denigrating, or violating the individual.

Regarding labor protection, Adamantia Group guarantees all its collaborators a suitable working environment that is fully compliant with current regulations, and absolutely rejects any form of exploitation, whether it be child labor, forced labor, or labor that is degrading to the individual.

Adamantia Group recognizes and supports labor protection in its entirety, as well as trade union freedoms, and occupational health and safety.

2.4 Respect for Corporate Assets

All Addressees of this Code must operate with the utmost respect for the internal procedures and corporate policies governing the use of corporate assets.

Each Addressee is deemed responsible for the proper use and care of the assets entrusted to them; this includes maintenance or reporting the need for maintenance.

Any improper use of corporate assets or failure to report damages or threats (both physical and cyber-related) will be sanctioned accordingly in compliance with current regulations.

Furthermore, Addressees are required to comply with current intellectual property laws, including the rights of third parties regarding websites, software, databases, and any material protected by copyright regulations.

2.5 Environmental Protection

For Adamantia Group, environmental protection is one of the fundamental principles that inspires and forms the basis of the Company’s activities.

Addressees of the Code must adopt a conscious behavior toward the ecosystem and avoid any type of risky action that could jeopardize the environment.

Should a violation of this principle occur, Addressees have the duty to promptly report it to the Company.

3. External Relations

3.1 Relations with Clients

Adamantia Group guarantees clients, both private and public, the full execution and fulfillment of contractually defined activities in accordance with the principles of fairness and good faith.

Relations with clients must always be based on sharing, collaboration, and transparency, and accompanied by the utmost respect and courtesy. Therefore, dishonest or unclear relationships, or those in which any of the parties are discriminated against, will be considered unacceptable.

3.2 Relations with Suppliers

Suppliers engaged by Adamantia Group have the duty to comply fully with the law and the core principles of this Code.

The selection and affiliation of suppliers, and consequently the purchase of goods or services, takes place in compliance with free competition, the quality of the good and/or service, and the mutual respect of such collaboration. Adamantia Group therefore sanctions any type of prejudicial behavior, favoritism, or discrimination.

3.3 Relations with the Public Administration

Adamantia Group guarantees full transparency in all relations with the public administration, public entities, and public officials or officers. In such relations, the following will not be tolerated under any circumstances:

  • Offering or promising, directly or indirectly, money or other benefits, in any form, to representatives of public entities or their family members;

  • Favoring or proposing employment and/or commercial opportunities to representatives of the Public Administration, other public entities, and/or their family members;

  • Exerting unlawful pressure or attempting to establish personal relations of favor, influence, or interference toward said individuals, such as to condition their actions, directly or indirectly;

  • Soliciting or obtaining confidential information that could compromise the integrity or reputation of the Company or a public entity, or otherwise cause unequal treatment or favoritism in public procurement procedures;

  • Agreeing to any request for contributions/sponsorships/donations that could influence or favor the Company in the event of audits/inspections/verifications by the Authorities.

Should any Addressee receive requests for undue money or other benefits from public entities, they are required to promptly inform the Company.

3.4 Relations with Information Channels and Media

Any communication made through any medium and/or tool by the Company must be clear, truthful, and transparent. Any interaction by Addressees with content published by the Company must comply with the core values set forth in this Code. The improper use or intellectual misappropriation of the Company’s content will be severely sanctioned.

The Company’s communication tools and media are managed exclusively by specifically designated individuals and must at all times comply with the corporate communication policy and common civic sense.

3.5 Relations with Political and Trade Union Organizations

Adamantia Group, in compliance with current laws, supports the free political and trade union affiliation of the Addressees, but does not in any way provide contributions aimed at financing political parties, movements, organizations, or political and/or trade union associations, nor their representatives or candidates.

3.6 Gifts, Gratuities, and Hospitality

Adamantia Group prohibits any Addressee from offering or receiving money, gifts, or personal benefits on behalf of the Company that could in any way create favoritism and/or discrimination.

Gifts, presents, or acts of commercial courtesy are permitted provided they are of modest value and, in any case, such that they do not influence and/or compromise the integrity and independent judgment of the recipients.

Anyone who receives gifts or presents exceeding normal commercial practices and courtesy, in compliance with corporate policies, will be required to immediately inform the Company.

3.7 Anti-Corruption and Anti-Money Laundering

Adamantia Group categorically rejects any behavior or activity with illicit purposes such as corruption, receiving stolen goods, and money laundering.

Addressees have the duty to report to the Company any relationships of affinity and/or kinship with representatives of the public administration.

Regarding anti-money laundering, Adamantia Group is appropriately equipped with tools to monitor and combat the phenomenon of money laundering. Monitoring is carried out by the Company before establishing a business relationship by verifying the available information, and during the relationship by regularly paying attention to invoices, payments, and any other legally relevant financial documentation.

3.8 Conflict of Interest

Adamantia Group is committed to applying its corporate policies so that conflicts of interest do not occur in any way.

All Addressees must refrain from situations that could undermine the Company’s business or reputation, even if only potentially or indirectly. This includes, but is not limited to, gaining personal advantages from the use of corporate assets or information encountered during the performance of business activities.

Any situation that may determine a conflict, even if only potential, with the interests of Adamantia Group must be promptly communicated to the Company.

4. Personnel Policy

4.1 Personnel Recruitment and Hiring

During the personnel selection and recruitment phase, Adamantia Group guarantees equality and equal opportunities for all candidates and rejects any form of discrimination against individuals.

Recruitment activities are subject to a thorough evaluation of candidates based on the requirements necessary to fulfill the open position and their compliance with global and departmental corporate policies.

4.2 Personnel Management

Adamantia Group guarantees all employees a relationship based on equality, equal opportunities, and mutual respect. Under no circumstances will discriminatory behaviors in the workplace be tolerated.

The Company will not maintain any relationship with Addressees who do not comply with the law, including, but not limited to, workers without valid residence permits and suppliers who employ irregular labor.

Adamantia Group is committed to ensuring that every employee can achieve professional growth through employment by means of training, information, instruction, and continuous development, recognizing that human resources constitute a fundamental pillar of corporate activity.

4.3 Occupational Health and Safety

Adamantia Group is committed to providing a safe and positive working environment and to supplying the tools necessary to comply fully with the regulations governing occupational health and safety.

The Company supports and promotes a corporate safety culture through training, prevention, and occupational medical check-ups, and all personnel are required to implement the prescribed measures.

4.4 Whistleblowing and Reporting of Misconduct

Adamantia Group will not tolerate, under any circumstances, discriminatory, harassing, or violent acts or behaviors against any individual internal or external to the organization.

In compliance with current regulations on whistleblowing, the Company protects the whistleblower and their privacy whenever a report of misconduct is submitted, guaranteeing investigation and resolution in accordance with corporate policy.

5. Accounting and financial transparency

5.1 Internal Controls

Adamantia Group reserves the right to internally monitor any non-compliance in order to maintain the efficiency of corporate activities and to avoid incurring risks that are even potentially damaging to the Company.

All Addressees, within the limits of their professional functions, bear responsibility for the operations and activities carried out and must be able to justify them by means of valid documentation.

5.2 Traceability of Operations

All accounting information concerning Adamantia Group is disclosed with the utmost transparency and honesty, just as every drafted financial document must meet the requirements of accuracy and truthfulness.

All accounting actions and operations related to Adamantia Group must be authorized, traceable, legitimate, and consistent, as well as supported by adequate documentation. This documentation must be preserved to guarantee, at any time, the execution of potential checks aimed at verifying its characteristics, reasons, and legitimacy, also for the purpose of identifying who authorized, executed, and verified the operations.

All personnel operating on behalf of Adamantia Group, including managing bodies and shareholders, are required to:

  • Comply with applicable laws and regulations, as well as the procedures and operational practices adopted by Adamantia Group and its constituent companies regarding accounting and the preparation of financial statements;

  • Ensure that no behaviors are engaged in that could prejudice the transparency and traceability of the information contained in the financial statements;

  • Cooperate so that management activities are correctly and promptly represented within the Company’s accounting records;

  • Disclose or make available externally administrative, financial, and accounting information only upon prior authorization from their supervisor;

  • Provide the requested information to individuals in charge of audits and to all parties authorized to access and review the documentation, based on their needs or otherwise necessary for the activities they conduct.

6. Confidentiality and data protection

6.1 Information Confidentiality

Adamantia Group guarantees total confidentiality regarding the information in its possession. Such information must be considered, in all cases, the property of the Company and cannot be communicated or disclosed to third parties or externally without specific authorization from the Company, in compliance with the organizational procedures in force.

Addressees must maintain the utmost confidentiality regarding any information they become aware of or otherwise possess during or in connection with the performance of their activities.

6.2 Data Protection

The processing of personal data carried out within Adamantia Group takes place in compliance with current regulations on personal data protection, in order to safeguard the right to privacy of all data subjects who interact with the Company in any capacity.

To this end, the Company has adopted and implemented specific policies aimed at guaranteeing the protection and security of information and personal data processed within its organization.

7. Monitoring, reporting and sanctions

7.1 Monitoring the Application of the Code

The rules and principles set forth in this Code are considered essential and fundamental; therefore, non-compliance will lead to the enforcement of appropriate sanctions provided for by current corporate policies and/or the competent Authorities.

Adamantia Group reserves the right to monitor the application of this Code at any time using appropriate means, and always in full compliance with the privacy of the Addressees.

7.2 Reporting Violations of the Code

Adamantia Group guarantees the proper observance of this Code. Addressees are required to promptly inform the Company of any violation and/or behavior contrary to the provisions contained in the Code of Ethics of which they become aware.

Reports may be submitted in writing to the following email address: info@adamantiagroup.com

7.3 Applicable Sanctions

Any violation by employees of the provisions contained in the Code of Ethics constitutes a breach of the obligations arising from the employment relationship and, consequently, a disciplinary offense punishable under the provisions of the applicable National Collective Labor Agreement (CCNL) and current legislation.

Such sanctions will be applied based on the significance and severity of the violation identified and verified.

Any behavior engaged in by consultants, suppliers, or any commercial partner of Adamantia Group that represents a violation of the provisions contained in the Code of Ethics shall be sanctioned in accordance with the specific clauses included in the relevant contracts. These clauses must be expressly accepted and must allow the Company to terminate the contract or, alternatively, to demand its fulfillment, without prejudice to the right to claim for damages.

8. Validity and updating of the code

8.1 Entry into Force

This Code of Ethics was adopted by resolution of the Board of Directors of each of the companies constituting Adamantia Group on January 22, 2025.

Its validity runs from the aforementioned date.

8.2 Update Policy

This Code may undergo amendments and/or updates. To consult the current version, please refer to the page published at the following URL: www.adamantiagroup.it/code-of-ethics-adamantia-group