PRINCIPLES

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1. RESPECT FOR THE PERSON: DPWAY does not tolerate any form of discrimination and harassment; DPWAY guarantees equal dignity and respect for all stakeholders by committing itself to creating and maintaining a work environment in which all employees and collaborators of the group are protected.

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2. FAIRNESS: DPWAY undertakes to maintain a conduct based on fairness with all stakeholders, especially with its employees/collaborators and customers. DPWAY recognizes equal opportunities and adopts fair attitudes towards customers, suppliers and competitors.

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3. MERITOCRACY AND PROFESSIONAL GROWTH: DPWAY undertakes to reward the merit of its employees through career advancements and also promotes skills and professional growth by paying particular attention to the constant updating of skills, to supporting career prospects and employability of its employees and collaborators.

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4. INTEREST OF THE CLIENT: DPWAY, acting in the interest of the client, does not consider only the individual client of the assignment, but the entire client-organisation in whose name and on behalf of which the assignment is assigned. DPWAY carries out the tasks entrusted to it by the customer with diligence and care, having regard to the trust that the customer places in DPWAY and bringing out its effective interests. DPWAY respects the customer's intellectual property and assets.

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5. TRUST AND TRANSPARENCY: DPWAY works to justify and safeguard the trust placed by constantly pursuing the interests of the customer. DPWAY carries out its business in compliance with the principle of transparency and is committed to bringing out any problems so that each stakeholder is put in a position to make their own choices responsibly and prudently.

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6. OBJECTIVITY AND IMPARTIALITY: In formulating its choices and solutions, DPWAY operates in an objective and impartial manner pursuing the client's interest and preventing conflicts of interest. Should such conflicts arise, the consultant will seek, through impartial agreements, to fairly balance the interests of all parties involved.

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7. CONFIDENTIALITY AND PRIVACY: DPWAY guarantees the confidentiality of all confidential information of stakeholders in its possession and operates in compliance with current legislation on privacy.

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8. FAIR COMPETITION: DPWAY competes with its competitors fairly and in the interests of the customer.

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9. LEGALITY: DPWAY's mandatory principle is compliance with the laws, regulations and rules in force in all the countries in which it operates.

DPWAY refuses assignments that involve the violation of laws.

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10. SOCIAL RESPONSIBILITY: DPWAY operates in the interest of the common good by directing the customer towards sustainable solutions from a financial, social and environmental point of view. The company undertakes to ensure that the consequences, even if not immediate, of the consultancy activities are socially responsible.

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11. CORPORATE IMAGE: All DPWAY employees and collaborators protect the image, reputation and brand of the company, as well as those of the customers with whom they operate.

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RELATIONS WITH STAKEHOLDERS

CUSTOMERS AND THEIR STAKEHOLDERS

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Professionalism, competence, availability, correctness and courtesy represent the guiding principles that the Recipients of the Code are required to follow in their relations with customers and, with a view to continuous collaboration and assistance, are aimed at guaranteeing satisfaction and its trust.

To protect the image and reputation of DPWAY, it is essential that relations with customers are based on:

• to full transparency and correctness;

• compliance with the law, with particular reference to anti-money laundering and anti-usury provisions;

• independence from any form of conditioning, both internal and external,

• through a lucid and truthful analysis of the assignment in question.

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The company only accepts assignments for which it is competent and, in any case, does not offer consultancy services if it is convinced that they are harmful to the company and/or to the client's organization, including its stakeholders.

Before proceeding with the offer, an assessment of the risks associated with the project is always carried out; this assessment concerns the following aspects:

• Potential problems, both economic-financial and technical and strategic;

• The availability of resources (both in qualitative and quantitative terms);

• The contents of the project in relation to potential technical or contractual issues;

• Any problems (if any) of a technical-organizational nature relating to the management of the project.

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Specifically, each offer from the consultant that has an economically significant impact for the client is accompanied by an analysis of the project that will take into consideration the nature, extent and dimension of the intervention offered, having regard to the direct and indirect effects of the results and the related consequences for all stakeholders.

Evidence of a high risk of the project may lead to interrupting the processing of the offer and abandoning the assignment.

In relations with customers and clients, the Company ensures correctness and clarity in commercial negotiations and in the assumption of contractual obligations, as well as the faithful and diligent fulfillment of the agreed obligations. Specifically, the company undertakes to provide information that is always complete, transparent and understandable to all, taking care that communication takes place accurately and faithfully, to allow recipients to make informed decisions regarding the activity carried out by the same and the services offered.

During the commercial offer phase with the customer, DPWAY undertakes to formalize the main aspects relating to the provision of the service in a transparent and clear way, defining:

• contents and methodological approaches;

• commitments and responsibilities;

• expected results (precisely quantified if a commitment to results is required);

• timing;

• checkpoints;

• deliverables;

• necessary resources in terms of means/persons.

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In situations where the customer is unable to verify the work, the company behaves in a professional manner and does not take advantage of it to gain undue advantages. In the event of unforeseen events causing the need to integrate the existing contract, the consultant promptly informs the client of the specific nature of these events and of the reason why they could not have been foreseen initially. In these cases, the Recipients do not seek to obtain unfair profits through expensive tariffs or unnecessary activities, but modify the initial project by proposing new contract terms which, probably, would have been accepted in an initial agreement.

On the basis of the consultancy offered to him, the client must be enabled to make his own decisions in a free, responsible and informed manner; for this reason, DPWAY favors the focus on the actual interests of the client organization and the actual objectives of the consultancy.

The Recipients of this code do not treat their own and/or potential customers arbitrarily and unequally, differentiating them on the basis of economic importance and the size of the order, but offer them a service that respects the agreed standards.

DPWAY does not discriminate against customers on the basis of religious, political, ethnic beliefs or sexual preferences but - while not expressing foreclosures towards any customer or category of customers - it does not maintain relationships, direct or indirect, with people of whom it is known, or only suspected, belonging to criminal organizations or which in any case operate outside the law.

The behavior adopted is based on respect for the confidentiality of the information acquired in the course of the activity, in compliance with the legislation on privacy in force.

Specifically, employees cannot disclose, through social media, company and/or customer information or, in general, information that has not yet been officially made public, nor open blogs and/or pages dedicated to the company without a prior and explicit consent from the Human Resources Office.

The recipients of this code are strictly prohibited from using confidential information of clients for purposes not connected with the exercise of their consultancy activity and/or outside the limits established by current legislation.

In the event that the Recipients hold influential positions in the context of corporate auditing processes that may have implications for the organization or distribution of resources, they undertake to act according to the principles of equality, impartiality, integrity, professionalism and non-discrimination.

Specifically, the Company must not accept, either from the client or from people belonging to the company with whom he has come into contact during the consultancy, gifts and/or donations that could even only induce the appearance of a limitation its independence and impartiality.

In general, forms of gift that can be, even if only indirectly, interpreted as exceeding the normal displays of courtesy allowed in commercial practice, or in any case aimed at obtaining favorable treatment for or from the Company, are not permitted.

It is absolutely forbidden for Recipients to request and/or accept, directly or indirectly, money and/or gifts and/or favors, in the event that this may appear as a counterpart to a service due in the context of carrying out the activity social of the Company.

If it is impossible to refuse or return the gift, or if the refusal could have negative consequences on the relationship, the person receiving the gift must promptly inform his direct superior, or the company contact person, who will evaluate the actions to be taken.

DPWAY undertakes to implement all necessary measures to prevent and resolve potential conflicts of interest. Specifically, in conducting any activity, circumstances in which the consultants find themselves in a situation, even if only potential, in which personal or family interests and/or activities condition the ability to operate in the total interest of the client must always be avoided.

In fact, in starting contractual relationships with new parties and managing existing ones, it is necessary, on the basis of public and/or available information in compliance with current legislation, to avoid:

• maintain relations with subjects involved in illegal activities, in particular connected with the trafficking of arms and drugs, money laundering and terrorism and, in any case, with subjects lacking the necessary requisites of seriousness and commercial reliability;

• maintain financial relationships with individuals who, even indirectly, hinder human development and contribute to the violation of fundamental human rights (e.g. by exploiting child labour, promoting sex tourism, etc.);

• maintain relations with subjects who do not comply with the provisions on health and safety in the workplace.

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The client's stakeholders, who are directly or indirectly affected by the decisions recommended during the consultancy activity, are represented by:

• the customer's employees and collaborators;

• consumers and users of the goods and services produced and distributed by the customer;

• the client's shareholders, in the case of a private company;

• customer suppliers.

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The Recipients of the code do not ignore the impacts on stakeholders in order to satisfy the client's requests or to satisfy the client's lack of vision.

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DPWAY COLLABORATORS AND EMPLOYEES

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Interpersonal relationships within the Company are based on the principles of respect, loyalty and transparency. No forms of exploitation, isolation, harassment or inducing stress are tolerated. The company protects the collaborator against any possible mobbing action.

The evaluation of the personnel to be hired is carried out on the basis of the correspondence of the candidates' profiles with those expected and with the specific needs of the Company. All personnel are hired with a regular employment contract, in accordance with the provisions of the law.

DPWAY ensures fair and equal pay and career opportunities for all employees. Through a fair and shared evaluation process, the profile of each employee is reviewed during a time frame defined by internal policies, recognizing any promotions and career advancements based on the results obtained and growth potential.

The collaborators' remuneration policy is based on recognition of merit for the contribution given in terms of effort and results; the project contact person discusses the evaluations and decisions concerning him with the employee in a transparent and objective way.

DPWAY respects the principle of equity in remuneration and incentives, the extent of which is determined taking into account the quality and quantity of the service and the results obtained, on the basis of objective and transparent evaluation criteria.

DPWAY does not improperly use forms of internships, with the sole purpose of making use of low-cost qualified work without actually offering professional growth and guaranteeing that they are remunerated.

DPWAY promotes gender equality and the enhancement of diversity, pursuing, also through the creation of training and professional qualification opportunities and within the limits of the collaborators' skills, effective equality in the opportunities for access to corporate responsibility functions.

With reference to decisions relating to personnel selection and career advancement of collaborators and employees, DPWAY does not discriminate on the basis of gender and sexual identity, race and religious and political beliefs. In this regard, it is specified that promotions and career advancements are expressly made explicit, and possibly recognized, to all those who cooperate in the creation of added value.

Employees are required to behave in a manner that is always respectful of the rights and personalities of colleagues, collaborators and third parties, regardless of their corporate role and the operating circumstances in which they find themselves. The respect and centrality of the human resource is an indispensable value for the company: the employee is required to comply with this value and the principles deriving from it, behaving with his colleagues in such a way as to favor the establishment and maintenance of a serene, collaborative and healthy environment.

All business decisions must be made in the exclusive interest of the Company. During the performance of their duties, the Recipients must avoid situations of conflict of interest deriving from their personal or family activities (economic or otherwise); in particular, anything that may interfere with one's ability to impartially make decisions in the best interests of the Company. Specifically, it is DPWAY policy not to employ within the same Company  children, brothers/sisters and spouses/partners more uxorio of employees in force.

Employees are expected to observe public behavior that respects DPWAY and the client organization they work for, being considerate of them and not harming them, both inside and outside the company context, as well as during or after working hours . Specifically, recipients have the duty to protect the corporate image by contributing to its enhancement and refraining from anything that, even indirectly, may affect the company's reputation.

These behaviors must be implemented in the most diverse public and/or private contexts, such as for example interviews with candidates, meetings or training courses, interactions with customers, publications on social networks, and - in general - in any case ( explicitly or implicitly) the company externally.

Any action must be based on respect for the person, the image, the good name of the company and its working environment. For this reason, the use and management of social media must ensure the protection of the company and the people who work there.

Furthermore, employees, when publishing their opinions, are required to specify that these thoughts are personal and do not in any way engage DPWAY's responsibility.

The private use of social networks - which can have an impact on the corporate image and the working environment - must be based on compliance with corporate principles and the awareness that their use implies personal responsibility. Employees are therefore required to avoid unethical attitudes and behaviors that could in any way damage or distort the corporate image.

The Recipients use the offices - both of the Company and of the customers - and company equipment with responsibility, order and respect, providing for the safekeeping of the company assets entrusted to them (such as personal computers, mobile phones and company cars), it being understood that DPWAY may ask the Recipients for compensation for any damage caused by negligence or carelessness.

Every employee and collaborator is required to work diligently to protect corporate assets through responsible behavior and in line with the operating procedures set up to regulate their use.

In particular, as regards the use of computer systems, everyone is responsible for the security of the systems used and is subject to the regulatory provisions in force and the conditions set forth in the license agreements.

Personal use of company equipment (PC, mobile phone, car) is permitted provided that it does not harm the efficiency and functionality necessary for carrying out work activities. In any case, the use of corporate e-mail must not be detrimental to the Company's image and reputation.

Each employee and collaborator is also required to make the necessary commitment in order to prevent the possibility of crimes being committed through the use of IT tools.

The Recipients are aware of the strategic and economic value, for the Company, of the methodologies, processes and work documents developed by DPWAY and therefore undertake not to disclose them externally and, in the event of termination of the employment relationship, to return to the Company any document or copy in their possession.

Furthermore, the Recipients must refrain from taking personal advantage from acts or information of which they have become aware during the performance of their duties.

Employees and collaborators are not permitted to use, in any form, the Company's name and trademarks for private purposes. The headed paper can only be used for communications signed by a delegate of the Company.

The Recipients of the code are aware and accept that all industrial and intellectual property rights relating to the intellectual creations and realizations and to the products and services deriving from the professional assignment, are to be understood as fully and totally owned and available by DPWAY.

For the decency and respect of colleagues and customers, Recipients wear formal attire both in the office and when visiting or traveling to customers.

DPWAY requires that its employees know and observe, as far as they are responsible, the provisions of the Code of Ethics and that, compatibly with individual possibilities, they promote knowledge of it among newly hired employees as well as third parties affected by the application of the Code of Ethics, with which they come into contact for reasons of their office.

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COMPETITORS

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DPWAY shares the value of fair competition, refraining from behaviors in contrast with community, national and association provisions for the protection of free competition.

DPWAY, therefore, does not undertake systematic actions of unfair competition aimed at depriving the competitor of human resources, confidential knowledge or relationships with parts of the customers with the sole purpose of making it impossible for him to have a presence on a market segment. Price reductions are not practiced, which cannot be sustained on the basis of the costs of the factors of production, for the sole purpose of eliminating competitors and acquiring a dominant market position, in order to be able to abuse it by making over-profits or by offering poor quality services to the detriment of the customer .

In the event that a collaborator who has signed a non-competition agreement with the previous consultancy firm switches to DPWAY, the latter undertakes not to cover the economic losses resulting from the violation of this agreement by the new collaborator.

In contacts with competing companies, the Recipients refrain from disclosing the terms and conditions (including financial ones) applied by the Company as well as from dealing with issues such as services and products offered, methodologies used, organization and internal policies.

DPWAY, in order to achieve the interests of its stakeholders, always works fairly with all the actors it meets during its tenure.

Furthermore, for assignments where DPWAY does not have all the operational skills or characteristics to manage the business, it undertakes to follow

the assignment also jointly or in association with other companies, even if competitors (eg ATI – Temporary Business Association).
 

DPWAY PROFESSIONAL AND COMMERCIAL SUPPLIERS / PARTNERS

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The supplier selection and selection processes are based on principles of legality, correctness and transparency.

The consultant does not take unfair advantage of contractually dependent relationships in which partners or suppliers may find themselves due to their insufficient information on the consultant's activities, especially when they establish long-term relationships with performance in advance of payments and investments by the supplier.

Every purchase in favor of the Companies  must be conducted with loyalty, integrity, confidentiality, diligence, professionalism and objectivity of judgement.

Recipients involved in the purchase process:

• are required to comply with the principles of impartiality, transparency, competition and independence in the exercise of the tasks and functions assigned;

• they must remain free from personal obligations towards suppliers;

• they must notify the Supervisory Body of any personal relationships with suppliers;

• must maintain relations and conduct negotiations with suppliers in order to create a solid basis for mutually convenient and long-lasting relationships in the interest of the Company;

• are strictly required to immediately report to the Supervisory Body any attempt or case of alteration of normal commercial relations;

• they must not offer goods or services, especially in the form of gifts, to personnel of other companies or entities to obtain confidential information or significant direct or indirect benefits, for themselves or for the Company;

• they must not accept goods or services from external or internal subjects against the release of confidential information or the initiation of actions or behaviors aimed at favoring such subjects, even if there are no direct repercussions for the Company.

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DPWAY informs suppliers and partners completely, truthfully and in a timely manner about:

• characteristics of the company and of the consultancy activity carried out;

• characteristics of the projects in which they are involved;

• forms and times of payment.

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Any changes to the tariff or services during the collaboration will be required in the event of circumstances that were unforeseeable at the time of signing the contract.

If new costs should arise from the reformulation of the collaboration contract, they will be divided by defining a corrective addendum in which reasons and facts not known at the time of stipulation are specified.

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SOCIAL COMMUNITY

 

DPWAY manages its business in a way that is compatible with the environment and the society that surrounds it.

DPWAY undertakes to operate for its customers also in activities in the context of projects aimed at energy efficiency interventions, providing analyses, services and measures to improve energy efficiency in customers' installations or premises.

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RELATIONS WITH THE PUBLIC ADMINISTRATION

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For the purposes of this Code, Public Administration means, in addition to any public body, also any independent administrative agency, natural or legal person acting as a public official or in charge of a public service or as a member of a Community body European Communities or an official of the European Community or an official of a foreign State.

It is not permitted, either directly or indirectly, or through a third party, to offer or promise money, gifts or compensation, in any form, or to exert unlawful pressure, or to promise any object, service, provision or favor to managers, or employees of the Public Administration or to persons in charge of a public service, or to their relatives or cohabitants for the purpose of inducing them to perform an official act or act contrary to the official duties of the Public Administration (since the purpose to favor or damage a party in a civil, criminal or administrative proceeding by bringing a direct or indirect advantage to the Company).

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Anyone who receives explicit or implicit requests for benefits of any kind from subjects of the Public Administration, as defined above, must immediately:

• suspend all relations with them;

• inform the Supervisory Body in writing.

  The provisions indicated in the previous paragraphs must not be circumvented by resorting to different forms of aid and contributions which, under the guise of assignments, consultancy, advertising, etc., have purposes similar to those prohibited by this paragraph.

  If commercial relations are undertaken with the Public Administration, including participation in public tenders, it is always necessary to operate in compliance with the law and correct commercial practice.

  In particular, the following actions must not be taken, directly or indirectly:

• offer or in any way provide gifts;

• solicit or obtain confidential information that could compromise the integrity or reputation of both parties.

It is not permitted to use or present false statements or documents or attest to untrue things or omit information to obtain, for the benefit or in the interest of the Company, contributions, loans or other disbursements however denominated granted by the State, by a Public Entity or by the Union European.

It is forbidden to mislead anyone with tricks or scams to procure an unjust profit for the Company  with damage to others.

The "unfair profit" can be direct or indirect and can include, in addition to contributions, loans and other disbursements granted by the State, by a public body and by the European Union, also concessions, authorisations, licenses or other administrative deeds.

Furthermore, it is forbidden to use grants, loans or other disbursements however denominated, granted to the Company by the State, by a Public Entity or by the European Union for purposes other than those for which they were assigned.

It is forbidden to alter in any way the functioning of a computer or telematic system or to illegally intervene in any way on the data, information and programs contained therein or pertinent to it, in order to obtain an unfair profit with the detriment of others.

The consultant refuses to pay sums of money or exchange any form of benefit with subjects active in the decision-making process to obtain the award of public contracts, and in general conforms his commercial conduct to the current principles regarding public, Community and national awarding.

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RELATIONS WITH THE MEDIA OF COMMUNICATION

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The criteria of conduct in relations with the media are based on principles of transparency, correctness and promptness.

Relations with the press are maintained exclusively by the Chairman and the Chief Executive Officers (subject to specific authorizations).

Recipients observe the utmost confidentiality with regard to information relating to customers. The only public and freely disclosed information on the Company is that contained on the website www.dpway.it.

Recipients refrain from providing other false or misleading information, rumors or news.

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RELATIONS WITH THE SUPERVISORY AUTHORITIES

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The Recipients are required to scrupulously observe the legislation in force in the sectors connected to their respective areas of activity and the provisions issued by the competent public supervisory authorities.

DPWAY and the Recipients act in compliance with the principle of sincere collaboration. Communications, reports and responses to requests sent to public supervisory authoritiesmust be prepared in compliance with the principles of completeness, integrity, objectivity and transparency.

It is forbidden to present untruthful facts even if they are the subject of an assessment of the company's economic, financial or equity situation or to conceal, with other fraudulent means, all or part of the facts to be communicated concerning the same situation.

In any case, it is strictly prohibited to knowingly obstruct, in any form, the functions of public supervisory authorities.

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RELATIONS WITH THE JUDICIAL AUTHORITY

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In carrying out the specific activities, DPWAY and the Recipients operate in a lawful and correct manner, collaborating with the Judicial Authority and the bodies delegated by the same if investigations are carried out against them. Under no circumstances does DPWAY or the Recipients engage in conduct that may interfere with or hinder the administration of justice. In particular, it is forbidden to induce people called upon to make statements before the judicial authorities that can be used in criminal proceedings against the Company and/or the Recipients, not to make such statements or to make false ones.

 

SANCTIONS SYSTEM IN THE EVENT OF VIOLATION OF THE CODE

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The violation of the principles established in this code compromises the relationship of trust between the company and its directors, employees, collaborators, consultants, customers, etc., therefore all violations will be evaluated promptly, and possibly countered through the adoption of disciplinary measures adequate and proportionate to the violation, regardless of the possible criminal relevance of such conduct and of the establishment of a criminal proceeding in cases in which they constitute a crime.

The content of any provisions imposed as a result of the aforementioned violations will comply with the provisions of current legislation, the individual contract and the disciplinary code. The measures may also determine the termination of the employment relationship and compensation for any damages suffered.

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APPROVAL OF THE CODE OF ETHICS AND RELATED AMENDMENTS

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The Code of Ethics is approved by the Board of Directors of DPWAY Srl

Any future updates to this Code of Ethics, due to regulatory adjustments, the evolution of civil sensitivity or otherwise, must be approved by the Boards of Directors and promptly disseminated to all Recipients.

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DISSEMINATION OF THE CODE OF ETHICS

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The task of supervising compliance with this Code belongs to the Supervisory Body for DPWAY Srl

In particular, any violation of the principles and provisions contained in this Code of Ethics must be promptly reported to the Supervisory Body.