Code of Ethics

General principles

Purpose and recipients of the code of ethics

The purpose of the Code of Ethics is to identify the principles and rules of conduct that should guide the behavior of Increso as a company, in every part and in its entirety, in carrying out its activities and managing internal and external relations. 

The Code of Ethics identifies and defines standards of behavior to which Increso as a whole must adhere, such as: 

• Legality; 
• Equity; 
• Professional integrity and fairness; 
• Fair competition; 
• Prevention of conflicts of interest; 
• Confidentiality; 
• Protection and enhancement of the person; 
• Occupational health and safety protection; 
• Environmental protection. 

The Code of Ethics is directed to: 

• Directors and component members of collegiate bodies; 
• Senior staff; 
• Employees (both fixed-term and permanent); 
• Contributors and consultants; 
• Suppliers of goods and services; 
• Any other person acting on behalf of Increso either directly or indirectly, permanently or temporarily. 

Recipients of the Code of Ethics are required to be familiar with its contents, to actively contribute to its implementation, to report any shortcomings and to observe, in any situation and context, its contents and inspiring principles, each within the scope of his or her specific functions, responsibilities and activities. 

Effectiveness of the code of ethics

The principles contained in the Code of Ethics integrate, from an ethical standpoint, the conduct relevant to the proper performance of activities by each person who is involved in any capacity in the activities of Increso. 

Failure to comply with the provisions contained and described in this Code of Ethics must be appropriately reported with consequent recourse to the actions that will be deemed most appropriate in relation to the seriousness of the report. 

Increso is committed to promoting a progressive dissemination and understanding of the Code of Ethics so that it formally becomes an integral part of the contractual obligations of all those who work in the interest of the company, pursuant to and in accordance with applicable law. 

Ethical principles

Transparency

The principle of transparency is based on the clarity and completeness of the information provided by the company regarding its activities and services. Increso is committed, both in its internal and external communications, to being clear and understandable in order to avoid that any lack of information may produce the attainment of illegitimate advantages.

Sustainability

Increso is committed to Carry out its activities respecting the principles of sustainable development, from an economic, social and of environmental protection. Therefore the pursuit of business results and economic efficiency should not be consideredati in opposition to social development and environmental protection, but must bene integral part.

Correctness

The principle of fairness includes the Company's respect for the rights of each person involved, far beyond mere compliance with current regulations and labor contracts, as well as the adoption of conduct inspired by the value of honesty. 

The principle of fairness must also be respected in terms of equal opportunity and the absolute rejection of any form of discrimination based on diversity of race, language, color, faith and religion, political affiliation, nationality, ethnicity, age, gender and sexual orientation, marital status, disability and physical appearance. 

Confidentiality

Increso ensures the confidentiality of the information and data being processed as well as the protection of information acquired in the performance of various activities. 

Without prejudice to the principle of transparency and the obligations arising from current regulations on the management of data and information, it is the obligation of all those who collaborate with Increso to ensure the confidentiality required by the circumstances for each piece of information acquired in the performance of their activities. All information, data, knowledge, and processes acquired in the course of one's work cannot be used, communicated, or disseminated without specific authorization from the Company in compliance with existing regulations and agreements. 

Competition

Increso recognizes as a value the principles of the free market and fair competition; it therefore acts in the market with respect for fairness, transparency and fair competition towards its competitors. Srefrains fromthe adoption of practices improper that may alter the proper functioning of market mechanisms.

Enhancement of human resources

People constitute a fundamental element in Increso's development and growth. The Company, while respecting individual ethical and physical integrity, fosters the professional growth of people with the aim of enhancing their professional skills, knowledge and work abilities. To foster the growth of human resources, Increso is committed to developing and maintaining a peaceful working environment in which everyone can work in accordance with the laws, principles and shared values. 

Update March 15, 2024. 

Criteria for conduct

Commitments of the company

Increso is inspired by the principles contained in this Code of Ethics, and is committed to directing its strategies according to values of loyalty and integrity in the pursuit of corporate objectives, fairness, respect for people and rules, and mutual cooperation. In particular, Increso's directors make a commitment to conduct the company responsibly in the pursuit of value creation goals. 

More specifically, Increso is committed to: 

• Ensure maximum dissemination and awareness of the Code of Ethics; 
• To clarify any doubts about the interpretation and implementation of the Code of Ethics, including with regard to its application in company procedures; 
• check for any reports of violations of the Code of Ethics and, in the event of an established violation, to take appropriate corrective measures; 
• Ensure safety in the workplace for its own personnel and third parties, committing itself to the utmost compliance with occupational safety regulations and promoting the safety of all places that constitute the work environment itself, even beyond the express obligations of the law; 
• Ensure respect for equal opportunity in all personnel management processes; 
• To spread a strong environmental culture and awareness, always operating in compliance with applicable laws and applying the best available technologies; 
• develop and maintain a healthy environment within the company, extending to the broader concept of preserving the environment for future generations. 

Duties of management

The behavior of each manager and company contact person conforms to the values of this Code of Ethics and sets an example for their collaborators with whom they establish relationships based on mutual respect and cooperation, fostering the development of a spirit of belonging to Increso. 

The dissemination of the company's values and employee motivation are essential elements in giving all Increso personnel and all those involved in the performance of activities an awareness of the contribution made by each person to the company's business and compliance with the Code of Ethics. 

Each manager and contact person supports the professional growth of the assigned resources, taking into consideration the aptitudes of each one in the assignment of tasks compatibly with the company's needs, in order to achieve real efficiency in the operational sphere. Increso's managers and referents are obliged to report to company management their own findings, or reports from employees or any other actor involved in Increso's activities, about possible cases of violation of the Code of Ethics so that appropriate verification activities can be undertaken. 

Duties of employees

Without prejudice to the provisions of the regulatory and contractual point of view regarding the duties of workers, professionalism, honesty, dedication, loyalty, spirit of cooperation and mutual respect are required of Increso's employees. 

Increso personnel are required to abide by the principles and guidelines contained in the Code of Ethics and to report to management any news of possible violations of the Code of Ethics. 

Company employees are responsible for gaining knowledge of the laws and regulations affecting their activities so that they can recognize potential risks and know when to seek company support.

Conflict of interest

In order to avoid the occurrence of conflicts of interest, every transaction and activity must be undertaken solely and exclusively in the interest of the company and in a manner that is lawful, transparent, fair and consistent with this Code of Ethics. 

Increso's personnel must avoid all situations and activities in which a conflict with the interests of the company may arise or which may interfere with their ability to make, in an impartial manner, decisions in the interest of the Company and in full compliance with the rules of this Code of Ethics. He or she is also required to avoid conflicts of interest between personal and family economic activities and the respective positions held within the organization. 

Any situation that may constitute or result in a conflict of interest must be disclosed to management in advance and in a timely manner. 

By way of example but not limited to, please note that they determine a conflict of interest situation: 

• Economic and financial interests exercised in competition or conflict with those of the company; 
• Performance of work activities, of any kind, at customers, suppliers, competitors of the company; 
• Acceptance of gifts, money, or any benefits from persons or companies that are or intend to enter into business relations with the company. 

Given the variety of situations that can arise in this context, if there is any doubt as to whether or not a conflict of interest has arisen, the resource involved should contact his or her supervisor or contact person or management directly for clarification. 

 Confidentiality and security

The staff of Increso is required tod comply accurately, punctually and diligently with the provisions of company policies and procedures inherent to data protection and information security. Compliance with the aforementioned company policies and procedures ensures the sound and proper pursuit of the objectives of confidentiality and security, which in a broader sense fall within the scope of this Code of Ethics.

Behavior and mode of operation

Increso in all business relationships is guided by the principles of fairness, correctness, transparency, efficiency and competition in the market. 

Increso's personnel including any internal and external collaborators whose actions may, even indirectly, be referable to Increso, shall follow proper conduct in the management of activities and relations with suppliers and customers, regardless of the importance of the activity handled. 

It is not permitted to offer money or gifts to directors, officers or employees of customers or their relatives, except for gifts of low value typically related to specific occasions such as gifts during the holiday season.  

Employees and contractors who are offered gifts from third parties, which cannot be attributed to normal acts of business courtesy, shall immediately inform their supervisor or contact person.  

Business activities must be carried out with professionalism, reliability, precision and courtesy. Knowledge sharing and a constructive working environment to promote mutual cooperation open to receiving new stimuli from outside must be ensured at all times. 

Free competition

Subject to compliance with applicable regulations on free competition, all Increso personnel are required to act in such a way as to achieve the best results in competition. 

It is not permissible to have exchanges of information or agreements with any competitor regarding strategies, proposed solutions, pricing models or sales conditions that may distort free competition. 

Any form of agreement, direct or indirect, that is made or put in place with competitors for the purpose of disrupting the conduct of public tenders is also prohibited. 

Relations with suppliers

In dealing with suppliers of goods or services, Increso personnel are obliged to: 

• Observe internal procedures for selecting and managing relationships with suppliers; 
• enforce contractual conditions and maintain an open dialogue to discuss any issues; 
• bring any problems that have arisen to the attention of management so that all the elements can be provided to enable them to assess the next steps to be taken. 

Customer relations

Customers represent the core element of business activities. 

What has been defined with customers must be carried out in a complete, precise and timely manner. Services or solutions provided to customers must always be tested in advance, must meet the characteristics of reliability and safety, as established in the design phase. It is the obligation of Increso personnel to: 

• Observe internal procedures for handling customer relations; 
• Provide accurate and comprehensive information about the products and services offered so that customers can make informed decisions; 
• Align customers transparently on the performance of services offered and solutions exercised. 

Relations with public institutions

In dealings with public administrations, Increso's personnel in charge of managing specific interactions are required, within the limits of their duties, to ensure that such interactions are for the purposes for which they were requested, and in any case to maintain accurate records of each transaction, ensuring maximum transparency and clarity. 

It is not permitted to give money or otherwise offer economic benefits or other types of benefits to persons in the Public Administration for the purpose of obtaining assignments or other personal benefits or for the company itself. 

No form of gift that could be construed as exceeding normal business practice or courtesy or otherwise aimed at acquiring favorable treatment in the conduct of any activity connected with the company is allowed. In this sense, a gift may be considered a "normal business practice or courtesy" if its value is less than €100.00. In any case, any form of gift directed to public officials or their family members that may influence evaluations and judgments for the purpose of obtaining more favorable treatment or advantages of any kind is prohibited. It is emphasized that a gift means any kind of benefit therein including by way of example free participation in conferences, training courses and job offers. 

The above definition cannot be circumvented or circumvented by resorting to the intervention of third parties. Indeed, not only illicit payments made directly to entities or their employees, but also illicit payments made to parties acting on behalf of such entities must be considered acts of corruption. 

Should an Increso person receive, from a member of a public entity explicit or implicit requests for benefits, he or she shall immediately inform management for appropriate verification and action. 

Relations with the media

All Increso personnel, including internal or external collaborators, must ensure that Increso's image is consonant with the prestige and importance of the company's role in the landscape of solutions and services companies in the area. 

Relations with the media are reserved exclusively for personnel defined within the company organization. Employees may not provide information or make statements on behalf of the company without the necessary corporate authorization. 

Accounting transparency

Every operation and transaction must be properly recorded, authorized, verifiable, legitimate, consistent and congruous. All actions and transactions must be properly recorded and it must be possible to verify the decision and authorization process. 

Increso personnel are required to cooperate to ensure that management facts are correctly and timely represented in the accounts. 

Adequate supporting documentation of the activity performed is maintained for each transaction so as to enable easy accounting records and reconstruction of the transaction, including reducing the likelihood of interpretative errors. 

Specific standards

Anti-corruption policies and guidelines

Increso stigmatizes and condemns bribery in all its forms, where bribery is defined as the offer or acceptance, directly or indirectly, of money or other benefits capable of influencing the recipient, in order to induce or reward the performance of a function/activity or the omission thereof. 

The Company therefore intends to identify a framework of ethical behavioral principles and rules for preventing and countering corruption. It is committed to preventing and countering the occurrence of wrongdoing in the performance of its activities, taking as one of its primary values that of business ethics, through which it conveys messages of loyalty, fairness, transparency, honesty and integrity. 

The main objectives of the corruption prevention policy are to: 

• Prohibit corruption in line with what is defined by national and international anti-corruption regulatory standards; 
• Promote and develop ethics in economic relations to protect the market, countering all forms of illegality; 
• Promote and develop commitment to continuous improvement in corruption prevention; 
• Encourage reports of any suspected attempted, certain, or alleged corrupt act through dedicated channels and methods that, while still in deference to the protection of the Company's reputation and image, allow, on the one hand, investigations and in-depth investigations to be carried out in order to assess their merits and prepare effective countermeasures and, on the other hand, to guarantee protection for the reporter from any form of retaliation. 

If a person has reasonable suspicion that misconduct has occurred or may occur, he or she may report it directly to management. 

It must, likewise, be emphasized, however, that any form of abuse of the report such as, by way of example, intentional defamation or slander, misuse or intentional instrumentalization of the institution covered by this Policy is firmly prohibited. 

The Company is committed to doing everything possible to ensure dissemination to all employees and contractors and to promote compliance with, implementation and adoption of this anti-corruption policy.  

Environmental protection

Increso has always paid the utmost attention to environmental issues and considers respect for the environment an ethical value as well as a distinctive competitive factor for corporate enhancement. 

By virtue of this, Increso achieved Synesgy certification in 2023 by conducting self-assessment on its level of sustainability, identifying strengths and improvement points, so as to take action and continue on the path of sustainable transition. 

Every activity in Increso is conducted with respect for the environment and the relevant legislation in force, and every person within Increso behaves responsibly and scrupulously with regard to environmental protection, health and safety. 

Strategies are then defined and implemented aimed at minimizing environmental risks and impacts and in accordance with the following principles: 

• Comply with current national and international environmental regulations; 
• Adopt and disseminate eco-efficient technologies; 
• Sustainably manage natural resources and energy, enhancing their proper use and increasing the use of renewable sources; 
• Design and implement business processes and activities with criteria that prevent pollution and possible accidental events while safeguarding the health and safety of employees and the public; 
• Raise awareness among management, staff and associates so that they are aware of the environmental aspects and impacts associated with their activities and are committed to operating in an environmentally friendly manner; 
• Adopt a spirit of cooperation with interested third parties for the enhancement of the environment. 

The above is also expected of Increso suppliers, with the goal of achieving a supply chain that operates in an environmentally friendly manner at every level. 

Whistleblowing

Increso has always been committed to promoting a corporate culture based on the principles of ethics and legality. 

Increso, in accordance with the provisions of Legislative Decree No. 24 of March 10, 2023, implementing Directive (EU) 2019/1937 and concerning the protection of persons who report violations of Union law and national regulatory provisions, provides an appropriate tool for reporting, including anonymously, the aforementioned violations, which can be reached at the following address: 

• https://increso.it/segnalazione-illeciti/ 

In particular, Increso has adopted a web platform managed by an external company that specializes in internal reporting systems for companies. Increso guarantees, through the use of the reporting tool provided, the confidentiality of the identity of the Whistleblower and the persons mentioned in the Report, as well as the confidentiality of the content of the Report and the documentation attached to it. 

In the reporting management phase, personal data may be processed by specifically authorized internal figures, service providers, or other external parties (e.g., managers of reporting management platforms), who will process the data as data controllers on behalf of Increso. 

If there is a need, personal data may be transmitted to third parties to whom communication is required by law (e.g. Judicial Authority, National Anti-Corruption Authority, etc.). 

Under no circumstances will personal data be disseminated.