Ethical code


Introduction

One of the main objectives of Focus Marketing is to guarantee the maintenance of the highest quality standards of the service provided. To increase the value, reputation and incentivize the use of market research services, it is important that information about the services is communicated accurately to both the business community and to customers and stakeholders, in compliance with laws, regulations and applicable government ordinances. Focus Marketing inspires its business to rigorous compliance with the principles of honesty, professionalism, transparency and confidentiality to safeguard the interests of the public and customers, in order to promote correct business practices.

Art. 1 (The values)

1. This code of ethics is based on the values ​​of moral integrity, transparency, respect for employees, social commitment and protection of health and safety.

Art. 2 (Purpose and scope of application)

1. This code of ethics contains the guiding principles of the behavior of individuals who work in various capacities at and for the company Focus Marketing srl and specifies the duties to which they are required; at the same time, this code of ethics declares the guiding principles of the Company’s behavior towards its main stakeholders.

2. The provisions of this code apply to all shareholders and employees who, at various levels of responsibility, contribute with their acts to the performance of the Company’s overall business.

This code also applies to consultants, experts and people who in any capacity collaborate with Focus Marketing in carrying out its activities.

Art. 3 (General provisions)

1. Who collaborates with Focus Marketing srl:

a) undertakes to respect the code and to conduct a conduct based on its values; avoid any situation of conflict of interest, even potential;

b) ensures that relations with colleagues are inspired by harmony and avoids acts or behaviors characterized by animosity and conflict;

c) conforms its activities to the criteria of correctness, cost-effectiveness, efficiency and effectiveness;

d) does not entertain or maintain relations with people or organizations that act on the borders or outside the law and does not participate in secret associations.

2. In external relations, those who work for and on behalf of the Company behave in such a way as to establish trust and collaboration on the part of those who come into contact with the Company itself, show courtesy and availability in communicating with customers, takes care of dealing with issues efficiently and promptly.

Art. 4 (Ethical responsibility towards third parties)

• Ensuring that each project is carried out in accordance with customer specifications. Appropriate procedures will be put in place to verify that customer specifications are met.

• Respect privacy regarding all techniques and methodologies and information considered confidential or proprietary. No information will be disclosed that could be used to identify customers or respondents without proper authorization.

• Ensure that the companies involved in the research activities, as well as their employees and subcontractors, take all reasonable precautions aimed at protecting the customer’s privacy.

• Do not disturb the client’s normal activities.

• Report the research results accurately and honestly. The research process must be described in sufficient detail to allow an experienced researcher to repeat the project if necessary. The results must be presented in a clear and transparent manner, including any aspects that may appear contradictory or unfavorable.

• Do not declare that you have qualifications, experience, skills or facilities that you do not
• Do not accept or ask others to knowingly violate the points of the Code.

• Communicate to each client that the client is responsible for the correct and legal use of the information provided through the search.

• Inform customers that all requests must comply with the Code and applicable laws, regulations, state and local ordinances.

• Inform customers that all requests must comply with safety regulations.

• Collect detailed project specifications from clients to ensure that data collectors can effectively complete projects. These specifications will be provided in writing to those in charge of data collection, who will then have to confirm their ability to implement them and their consent to respect them.

• Do not intentionally abuse the trust of the business community. Under no circumstances may the research information be used to intentionally mislead the corporate community. Attempts to abuse in the corporate community undermine the credibility of the entire sector.

Art. 5 (Moral integrity)

1. Employees and all subjects who in various capacities collaborate with Focus Marketing srl undertake to:

a) constantly maintain behavior inspired by sincerity, honesty and rectitude;

b) propose and accept assignments with the awareness of having the skills necessary to perform the service;

c) not to influence the choices of customers with compensation of any kind;

d) inform its customers of assignments of the same nature with possible competitors;

e) not to accept compensation of any kind from its suppliers when it comes to proposing or recommending goods or services supplied by them;

f) refrain from offering employment to the customer’s staff, either by themselves or by third parties, except in the case in which the application is proposed or otherwise approved by the customer. Any unsolicited applications will be evaluated ensuring the protection of the client and the confidentiality of the staff themselves.

g) not to use confidential customer information to make profits or private interests.

h) to respect, in carrying out its activities, the dictates of Integrity Pacts or other codes of conduct, possibly signed by the Company with other public or private subjects and, in this sense, to inspire its activities to the principles of honesty, transparency , loyalty, integrity and correctness, in compliance with the laws and regulations in force.

2. Any negotiation, request, or institutional relationship with the Public Administration must be aimed at maximum transparency and must be conducted in compliance with the functions and roles attributed under the law, as well as in a spirit of maximum collaboration.

The people involved must not try to improperly influence the decisions of the counterparties, nor engage in illegal behavior, such as the offer of money or other benefits, which could alter the impartiality of judgment of the representative of the Public Administration. Any act contrary to the regulations in force, including the use of altered or falsified declarations or documents, the omission of information or, in general, the carrying out of tricks and deceptions, aimed at obtaining concessions, authorizations, loans, contributions, also constitutes illegal behavior. by the European Union, the State or other public body.

Art. 6 (Transparency and Confidentiality)

1. Employees and all subjects who in various capacities collaborate with Focus Marketing srl undertake to:

a) ensure the truthfulness, transparency, accuracy and completeness of the documentation and information provided in carrying out the activity within its competence;

b) provide the customer with the widest possible information so that the customer can make their own choices, ensuring that the references are truthful and verifiable;

c) provide the customer, at any time, with the documentation necessary to verify the progress of the work, the reasons for the choices made and the support necessary for their interpretation;

d) to keep and keep the documentation in the company, easily available and filed in an orderly manner according to logical criteria;

e) in accounting for management facts, comply with current legislation and internal procedures so that each operation, in addition to having been authorized, is properly recorded, verifiable, legitimate, consistent and congruous;

f) respect office secrecy and keep news and information learned in the exercise of their duties confidential;

e) consult only the documentation directly related to your business and make use of it in compliance with official duties, allowing access to those who have the right to do so and in accordance with the requirements issued by the Company.

2. The Company condemns any conduct aimed at altering the correctness and truthfulness of data and information contained in financial statements, reports or other corporate communications required by law or disclosed to the public or directed to the supervisory authorities or auditors.

3. The Company, in carrying out its business, protects the personal data of employees, collaborators and third parties, avoiding any improper use of their information, in compliance with internal procedures and reference regulations. It also ensures the correct management of confidential information acquired during work. The Company expects similar behavior from third parties who come into possession of this information.

Art. 7 (Respect for employees)

1. The Company is aware that the achievement of corporate goals and the maintenance of quality standards depend on the presence of qualified and loyal employees and collaborators who constitute an intangible asset of primary value.

From this point of view, the creation and maintenance of a serene and proactive work environment are considered factors of primary importance and to be achieved also through respect for the privacy of one’s employees and the protection of equal opportunities, guaranteeing growth paths based exclusively on personal merits and skills, and aimed at consolidating the level of professionalism of each.

2. The Company guarantees its employees training courses aimed at combining the needs of company growth with the training needs expressed by the workers, and makes available the appropriate refresher and professional development tools.

3. In the selection phase and in all phases of career progression, the Company proceeds with absolute impartiality, autonomy and independence of judgment, making assessments based on the correspondence between expected profiles and required profiles, on transparent and verifiable considerations of merit, and adopts appropriate measures to avoid any form of discrimination and favoritism, not allowing distinctions for reasons of nationality, skin color, religious belief, political affiliation, trade union or sex.

4. The staff is hired with regular employment contracts. In no case is an irregular form of intercourse tolerated.

5. The Company always considers the protection of workers to prevail over any economic consideration.

Art. 8 (Protection of health and safety)

1. The Company undertakes to ensure a work environment compliant with current safety and health regulations, by monitoring, managing and preventing the risks associated with the performance of the work activity. Consistently with this objective, the employees, and all the figures involved (head of the prevention and protection service, the workers’ safety representatives, etc.) collaborate, within the context of their respective functions and responsibilities, to eliminate or progressively reduce risks at source and improving working conditions.

2. The Company requires that each employee and collaborator personally contribute to keeping the work environment safe and clean and to promote a climate of mutual respect by paying the utmost attention to the rights, personality and sensitivity of colleagues and third parties, regardless of their hierarchical position and without creating discrimination of any kind or distinctions of sex, race, language, religion, political opinions, personal and social conditions.

Art. 9 (Social commitment)

1. The Company is committed to promoting equal opportunities and the enhancement of contexts from a gender perspective.

2.The Company in carrying out its activities undertakes to respect the principles of Corporate Social Responsibility, paying attention to the impacts generated on people, territories, the environment, in the medium and long term by its choices and actions.

Art. 10 (Obligation to respect the code by employees and collaborators in any capacity)

1. Employees undertake to comply with this code.

2. Collaborators in any capacity, upon receiving the assignment, undertake to comply with this code.

4. In the event of a possible violation of this code, the President carries out the necessary checks in compliance with the adversarial principle and proposes to the Shareholders’ Meeting the possible adoption of disciplinary measures and the revocation of the appointment respectively.

5. The resolutions adopted by the Assembly are communicated to the interested parties.

Naples, 04.12.2019

The Code of Ethics of the Company Focus Marketing srl can be downloaded at this link.

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