Ethics in entrepreneurial activity is an approach of utmost importance for the success and credibility of a company towards customers, suppliers and, more generally, towards the entire social context in which it operates.
Dogma Investigative Agency - Private Investigations and Security - has participated in the examination and drafting of this Code of Ethics. The purpose of the Code is to establish the principles of correctness, loyalty, integrity, and transparency of rights, of the way of operating and managing relations both within and with third parties.
Recipients of the Code of Ethics are all managers, employees and collaborators of the Company, as well as external collaborators. The Code applies to all business activities performed.
Infringing the rules contained in this Code will damage the relationship of trust established with the company and will be subject to the penalties provided. The application of the Code of Ethics is delegated to the Chief Executive Officer or to designated subjects.
2. GENERAL PRINCIPLES
The recipients of this Code of Ethics must abide by the following guiding principles:
- acting in compliance with the law and regulations in force;
- treating customers, employees, external collaborators, suppliers, the surrounding community and institutions, as well as any third party, with honesty, fairness, impartiality and without prejudice;
- operating loyally towards other operators present in the Company's environment;
- protecting health and safety of oneself and third parties;
- maintaining the confidentiality of information regarding the company, its know-how, employees, customers and collaborators.
- avoiding or declaring in advance any conflicts of interest existing within the company;
- using the intellectual and material assets of the company in respect of their intended use.
3. ETHICS OF THE RELATIONSHIPS WITH THIRD PARTIES
3.1 RELATIONSHIPS WITH CLIENTS
The company’s aim is to constantly preserve the quality of the relationships it builds with its clients, improving them constantly. Professionalism, skills, availability, correctness and courtesy are the guiding principles that employees are expected to follow while dealings with clients.
All behaviors must respect the confidentiality of all the information obtained during the work, as well as the current legislation on privacy.
All relations with the clients are based on full transparency and fairness, in compliance with the applicable regulations (mainly referred to the processing of personal data), and free from any form of conditioning, both internal and external.
Clients represent the most important assets of the group. Employees and collaborators, in relation to their duties, offer their services by working with professionalism, prudence and common sense.
All clients are equally important within our Company and therefore, beyond their specific needs, must receive an equal care and attention.
3.2 RELATIONSHIPS WITH PROVIDERS
The selection of suppliers and the determination of the purchase conditions must be based on an objective evaluation of the quality, of the price of requested goods and services, of the ability to provide and ensure prompt and adequate levels of goods and services for Companies. No supplier must be chosen over another because of personal reasons, favoritism, or benefits other than for the exclusive interest and benefit of the Company.
3.3 RELATIONS WITH EMPLOYEES
Human resources are an essential factor for the existence, development and success of any company. For this reason, Dogma Investigative Agency – Private Investigation and Security – protects and promotes human resources’ value, in order to improve and increase the assets and competitiveness of collaborators within the organization of the company.
Dogma offers equal opportunities to all employees on the basis of their professional skills and personal abilities, without prejudice, in terms of religion, race, political, union and sex belief.
Therefore, the company choses, employs, pays and organizes the employees according to their merits and skills.
Work place is not only adequate for our employees’ personal security and health, it enhances mutual collaboration and group spirit by respecting one’s moral personality, without prejudice and threats, illegal conditioning and illicit inconvenience.
3.4 RELATIONS WITH OPERATORS
Dogma shares the value of loyalty, refraining from behaviors that would go against European and national free competition protection provisions.
3.5 RELATIONS WITH THE PUBLIC ADMINISTRATION
In its relation with the Public Administration, the Agency pays special attention to each act, behavior and agreement, in order to have the maximum transparency, traceability, correctness and legality. During business negotiations, requests or commercial relations with the Public Administration no behaviors will be held, directly or indirectly, so as to affect the counterparty’s decision. In particular, it is not permitted to examine or propose job offers that may advantage employees of the Public Administration in a personal capacity, or solicit or obtain confidential information that could compromise the integrity or reputation of both parties. If the company uses a consultant or a third party to be represented in relations with the Public Administration, the same directives apply to the employees of the company in relation to these subjects and their personnel.
3.6 GIFTS AND BENEFITS
Gifts that may exceed normal commercial practices or courtesy, or gifts that may aim at obtaining favorable treatment in the conduction of any activity related to the Agency are not allowed. In particular, any gifts to public officials or their family members, which might influence their independent judgment or induce them to ensure any sort of advantage, is forbidden.
4. HEALTH AND SAFETY PROTECTION ON WORKPLACE
Recipients of this Code contribute to health and safety prevention and protection towards themselves, their colleagues and third parties, without prejudice to individual responsibilities in accordance with the applicable legal provisions.
They must also maintain an atmosphere of mutual respect for dignity, honor and reputation of each person, while respecting the existing organization within the company.
Within the scope of company activities, there is an absolute general prohibition of alcohol abuse or use of drugs and a ban on smoking in the workplace in compliance with the law.
5. MANAGEMENT OF INFORMATION AND DOCUMENTATION
5.1 USE AND MANAGEMENT OF COMPANY INFORMATION
All information and other material handled by Recipients of this Code in relation to their work or professional activities is strictly confidential and constitutes the company’s property.
This information may include present and future activities, including news not yet disseminated, information and announcements.
Those who, by virtue of the exercise of their functions have access to privileged information regarding the company (eg: information regarding acquisition projects, strategic plans, business strategies, etc.), cannot use them to their advantage, or to the advantage of family members and in general of third parties, but exclusively for the execution and within the scope of their office or profession.
They must also pay particular attention not to disclose privileged information and to avoid any improper use of such information.
Even information and/or any other kind of news, documents or data that are not in public domain must not be disclosed, nor used and even communicated for different purposes, without specific authorization.
It is in any case recommended a desirable privacy with regard to information concerning the company and the work or professional activity.
5.2 USE OF INFORMATION RESOURCES of information resources
IT and telematic resources are a fundamental tool for the correct and competitive operation of the company, ensuring the speed, breadth and correctness of the information flows necessary for the efficient management and control of company activities.
All information that resides in the company's IT and telematic systems, including electronic mail, must be used exclusively for the performance of company activities, within the methods and limits indicated by the company.
To ensure compliance with regulations on individual privacy, we pursue a correct and limited use of IT and telematic tools, avoiding any use not permitted. The use of IT and telematic tools is subject to monitoring and verification by the company.
5.3 ACCOUNTING BOOKS AND COMPANY REGISTERS
Dogma - Private Investigations and Security - accurately and completely records all company activities and operations, according to the principles of maximum accounting transparency.
6. COMPANY CONDUCT
Dogma believes that corporate conduct must always be pursued in the formal and substantial respect of the law, maintaining a transparent and reliable conduct in full cooperation with the authorities in charge.
Recipients of the Code must avoid all situations and activities in which there could be a potential conflict of interest among the personal activities and the professional duties. The recipients are obliged to declare any existing conflict of interest, before the start of the activity concerned. In particular, managers and employees who are recipients of this Code must declare to the Administration Office whether there are situations of conflict or any other situation potentially lesive to the company's operations.
8. STRUCTURE OF CONTROL
8.1 VALIDITY OF THE ETHICAL CODE
The violation of the provisions of this Code will constitute a breach of the contractual obligations of the employee and will entitle the company to apply the disciplinary sanctions provided, in addition to all other legal consequences eventually provided.
8.2 VERIFICATION OF THE EFFECTIVE APPLICATION OF THE CODE OF ETHICS
The application of the Code of Ethics is delegated to the CEO.
This Code of Ethics is given the maximum dissemination to all recipients. The Managing Director is entrusted with the tasks of:
- supervising compliance with the Code and disseminating it to all recipients;
- ascertaining any violation of the Code and inform the competent corporate bodies accordingly;
- proposing changes to the content of the Code.
8.3 VIOLATIONS OF COMPANY RULES AND NON-ETHICAL BEHAVIOR
Cases of violation of legal or ethical regulations must be promptly reported in writing, in a confidential form, to the CEO's office.
8.4 DISCIPLINARY SANCTIONS
Disciplinary sanctions envisaged in the event of violation of the regulations contained in this Code are intended to contribute to the effectiveness of the Code itself and to the control action of the CEO's office. They must be proportionate to the gravity of the violation, to the recidivism, to the lack or to the degree of the fault, in observance of the discipline referred to in art. 7 of the Law of May 20, 1970, n. 300 and the provisions contained in the employment contracts.
The application of the disciplinary system is autonomous with respect to the conduct and outcome of any criminal proceedings initiated by the competent judicial authority.
With regard to suppliers, collaborators and external consultants, the violation of the precepts of this Code is sanctioned by the termination of the contract in place, without prejudice to the Company's right to request compensation for damages that occurred as a consequence of said behaviors.