18 - RELATIONS WITH ASSOCIATIONS, TRADE UNION ORGANIZATIONS AND POLITICAL PARTIES

 

18.1 Company Objectives

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The Company recognizes, to the maximum extent permitted by the laws of each system in which it operates, freedom of thought, expression and the right of association as fundamental prerogatives of individuals.

However, the Company maintains a position of autonomy and independence with respect to any political organization or trade union.

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18.2 Definition

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By Associations we mean a group of people gathered, organized and working for the pursuit of a common goal.

Trade union organization must be understood as the set of people who represent and carry out an activity aimed at protecting the rights of the category.

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By political party we mean an association between people united by the same political purpose or by a common vision on fundamental questions of the management of the State or even only on specific and particular themes.

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18.3 Principles and rules of conduct

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The rules indicated below apply to any movement, organization or association which has political aims or which can be traced back to movements, organizations or associations which pursue political aims.

In order to avoid possible forms of corruption, the Company does not disburse, directly or indirectly, contributions to finance organizations, parties, movements, political or trade union committees, or their representatives or candidates.

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Furthermore, the Company does not finance associations or sponsor events or congresses that have political propaganda as their purpose.

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19 - RELATIONS WITH INTERNATIONAL OPERATORS AND BUSINESS ACTIVITIES ABROAD

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19.1 Company Objectives

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The Company repudiates the commission of crimes of any kind. In order to minimize the danger of committing crimes of a transnational nature, the Company undertakes to guarantee that all relations, including those of a commercial nature, with subjects operating at an international level take place in compliance with the applicable laws.

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19.2 Definition

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Relations with international operators mean all relations (such as, by way of example, commercial, contractual and institutional relations) maintained with public or private entities outside Italy.

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19.3 Principles and rules of conduct

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The Company undertakes to take the necessary precautions to verify the reliability of these operators.

Furthermore, as far as it is responsible, the Company undertakes to collaborate, with correctness and transparency, with the Authorities, including foreign ones, which may request information or carry out investigations regarding the relations between the Company and international operators.

 

20 - RELATIONS WITH LOCAL COMMUNITIES

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20.1 Company Objectives

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It is the Company's commitment to actively contribute to the promotion of quality of life, to the socio-economic development of the communities in which the Company operates and to the formation of human capital and local skills, at the same time carrying out its business activities in a manner compatible with a fair business practice.

 

20.2 Definition

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By local communities we mean a set of individuals who form a recognizable group, united by organisational, linguistic, religious, economic ties and common interests.

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20.3 Principles and rules of conduct

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The Company's activities are carried out in the awareness of the social responsibility that the Company  has towards all its Stakeholders and in particular the local communities in which it operates, in the belief that the capacity for dialogue and interaction with civil society they represent a fundamental value of the company. The Company respects the cultural, economic and social rights of the local communities in which it operates and undertakes to contribute, where possible, to their realization, with particular reference to the right to adequate food, drinking water, at the highest attainable level of physical and mental health, decent housing, education, culture, abstaining from actions that may hinder or impede the realization of these rights.

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The Company promotes conditions of transparency in the information addressed to local communities, with particular reference to the topics of greatest interest to them, in order to take into due consideration the legitimate expectations of local communities in the conception and conduct of company activities in order to promote mechanisms adequate redistribution of profits deriving from the activities.

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The Company therefore undertakes to disseminate knowledge of corporate values and principles internally and externally, also by establishing adequate control procedures, and to protect the specific rights of local populations, with particular reference to their cultures, institutions, ties and lifestyles.

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The Company also undertakes to favour, support and promote the activities that bear witness to its commitment to take an active part in satisfying the needs of the communities in which it is present.

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21 - RELATIONS WITH THE PRESS AND OTHER MEDIA OF INFORMATION AND PROTECTION OF CONFIDENTIAL INFORMATION

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21.1 Company Objectives

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The Company considers communication with the public an indispensable factor for its growth and for the fulfillment of its mission, being the instrument for transmitting the Company's values and image to the outside world.

However, the Company believes that confidential information is part of the company's assets understood in its broadest sense and as such must be protected, since the loss of such information could have serious consequences for the Company.

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21.2 Definition

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The rules and principles indicated below apply, by way of example but not exhaustively, to the relations between the Company and television and radio broadcasters, magazines, newspapers, information websites and press agencies in relation to facts, news and information concerning, even indirectly, the Company.

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Confidential information is any personal, technical, scientific or commercial information that is not in the public domain. They include, but are not limited to: information regarding product prices and costs, product compositions and scientific research results; information on production methods and sales and marketing plans and strategies; information on contracts in progress or in the process of being concluded; customer, consumer, patient and supplier lists and information; financial information; inventions, trade secrets; the know-how; unforeseen products and developments.

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21.3 Principles and rules of conduct

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The Company considers the dissemination of correct, complete and truthful information on all company facts, and the maintenance of confidentiality on the same, when necessary, as a prerequisite for creating and maintaining a relationship of transparency and trust with all Recipients.

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The Company addresses the press and communication bodies in general solely through the corporate bodies and corporate functions or those of their own group to which they belong, in an attitude of maximum correctness, availability and transparency, in compliance with the defined communication policy from society.

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Information and communications relating to the Company and its activities and intended for the outside world must be accurate, truthful, complete, transparent and consistent with each other.

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Personnel cannot issue statements and disclose data relating to confidential information of the Company.

Third Party Recipients cannot issue public statements, data and information regarding the Company.

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22 - TRANSPARENCY AND EFFICIENCY

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22.1 Company Objectives

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The Company considers the transparency and efficiency of business process management two essential factors for its success and for the fulfillment of its mission, contributing significantly to the creation of value and a feeling of trust on the part of the market, suppliers, of customers and consumers.

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22.4 Definition

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Transparency means the clarity and accuracy with which operations, transactions and any other information relating to the Company must be recorded.

By efficiency we mean a way of managing company activities based on cost-effectiveness, while respecting the highest quality standards.

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22.3 Principles and rules of conduct

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Recipients, in carrying out their duties, are required to provide truthful, accurate, complete and understandable information.

Every operation and transaction must be properly recorded and authorised. It must also be verifiable, legitimate, consistent and fair.

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All decisions and operations must be adequately recorded and it must be possible to verify the process of their deliberation, authorization and implementation, also through adequate documentary support.

The Company's archives must be complete, orderly and readily accessible.

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Any type of correspondence, whether by letter, fax, e-mail or even verbal comments, must be given in an appropriate tone and manner and must be clear and coherent in content so that it can be shown or delivered to a third party (e.g. a investigative authority, a court, other government institutions or auditors).

Every business activity must be based on economy in the management and use of resources, always in compliance with the highest quality standards.

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Everyone is the responsible custodian of the company resources and assets (tangible and intangible) assigned to them.

It is forbidden to solicit, use or remove Company assets for personal use, damage or destroy Company assets, or make, or permit others to make, improper use of assigned Company assets or Company resources.

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23 - FINANCIAL STATEMENTS AND OTHER ACCOUNTING DOCUMENTS

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23.1 Company Objectives

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In the context of relations with shareholders and with the market, the Company considers correctness in accounting management to be a fundamental value and pays particular attention to the preparation of the financial statements and other accounting documents.

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23.2 Definition

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The Balance sheet is defined as the document which summarizes a patrimonial, economic and financial situation in a given historical moment.

An accounting document must be understood as a title or a written declaration relating to an administrative fact to be recorded for accounting purposes in a company.

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23.3 Principles and rules of conduct

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The principles and rules of conduct set out below apply to the preparation of the financial statements, interim financial statements, balance sheets, reports and other corporate communications required by law and addressed to shareholders, creditors or the public regarding the economic, patrimonial or financial situation of the Company.

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The Company ensures that all financial transactions and, in particular, any disbursement of funds by the Company, are correctly recorded in the accounting books, according to the principles of transparency, truthfulness, accuracy and completeness.

Each member of Staff is required to collaborate, within the scope of their respective functions and responsibilities, so that management facts are represented correctly and promptly in the accounting records.

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It is forbidden to engage in conduct aimed at undermining the transparency and traceability of financial statement reporting and, in particular, it is forbidden to commit infidelity in the preparation of accounting documents and in their conservation.

With reference to each operation, adequate supporting documentation of the activity carried out must be kept, so as to allow easy and timely accounting entry; the identification of the different levels of responsibility and of division and segregation of duties; the accurate reconstruction of the operation, also to reduce the probability of material or interpretative errors.

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Any Recipient who becomes aware of omissions or falsifications in the accounting or of the documentation on which the accounting records are based must report the facts of which he is aware to his superior, or to the body to which he belongs.

Each Personnel member assigned to present information relevant to financial reporting and intended for public disclosure is responsible for ensuring that such information is complete and accurate.

Each member of Staff is required, within the scope of their respective functions and responsibilities, to collaborate with the internal control bodies and with the Auditors and to indicate to them any fact, circumstance or behavior that does not comply with the principles established in this Code, as well as to report regarding any transaction that does not appear to correspond to a legitimate commercial or financial purpose.

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24 - INVITATIONS TO CONFERENCES AND CONGRESSES

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24.1 Company Objectives

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It is the Company's objective to ensure that the participation and organization of conferences, congresses and scientific meetings are carried out according to the principles of fairness and professionalism.

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24.2 Definition

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By conferences and congresses we mean those conventions, congresses and scientific meetings that focus on issues relating to the use of medicines and other products.

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24.3 Principles and rules of conduct

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Without prejudice to the regulatory provisions in force on the subject:

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• the agenda of conferences and congresses must be in line with the qualifications of the participants and with the medical-scientific objectives that these conferences and congresses set for themselves;

• the location of these events is such that it can be easily reached by the participants, as well as appropriate for the type of meeting and audience

• the coverage of travel expenses for any participants accompanying the participants is not borne by the Company.

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If the local regulations in force in a particular state are more restrictive than the company rules, the local legislation must be observed.​

25 - GIFTS AND ACTS OF COURTESY

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25.1 Company Objectives

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The Company undertakes to manage its activities and relations with any third party, regardless of the private or public nature of the latter, in compliance with the criteria of correctness, transparency and independence by leveraging high levels of service and quality and without accepting or promise anything of value that could in any way affect the outcome of the transaction.

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25.2 Definitions

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Tribute must be understood as a gift legitimated by reasons of courtesy, deference or even commercial propaganda.

By act of courtesy we mean the disinterested act performed in the context of polite conduct. There is talk, by the way, of "wide social etiquette".

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25.3 Principles and rules of conduct

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Except in the cases indicated below, it is forbidden to accept, offer or promise, even indirectly, money, gifts, goods, services, favors or other benefits in relation to relationships maintained with any third party, regardless of the private or public nature of the latter, to influence their decisions, in view of more favorable treatment or undue performance or for any other purpose, including the performance or omission of acts inherent to their functions.

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If connected to the aforementioned relationships, any requests or offers of money, gifts (with the exception of those of modest value, by which we mean those of use in relation to the circumstances), favors of any kind, forwarded or received from subjects operating for the Company, must be promptly brought to the attention of the Company.

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Gifts and acts of courtesy, including invitations to lunches, dinners or social events, towards third parties, regardless of the private or public nature of the latter, are allowed only if they are of modest value and of such a nature that they cannot in any way the independence of the interested parties and cannot be interpreted as a means to obtain advantages improperly.

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Such gifts and acts of courtesy, including invitations to lunches, dinners or social events, must be previously authorized by one's superior and are permitted under the following conditions:

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• that the gift or courtesy is permitted by law;

• that the gift or act of courtesy is part of a working relationship inspired by fairness;

• that the gift or courtesy is not contrary to industry practices;

• that the gift or act of courtesy, should it be made public, cannot constitute a cause of embarrassment for the Company.

 

 

 

REPORTING ANY VIOLATIONS OF THE CODE OF ETHICS AND ASSISTANCE TO STAFF

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If a person required to comply with this Code of Ethics becomes aware of a fact and/or a circumstance capable of integrating the danger of their violation, he is required to promptly report it to the Company.

In particular, a special e-mail box is activestudiolegale@avvrocca.itwhere to send any reports regarding non-compliance with this Code, which will also be used for receiving reports of an anonymous nature, or those in which it is not possible to trace the identity of the sender.

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The Company takes steps to ensure that those who have made such reports are not subject to retaliation, discrimination or, in any case, penalties, thus ensuring the adequate confidentiality of these subjects (unless there are any legal obligations that impose otherwise).

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If a person required to comply with this Code of Ethics wishes to receive clarifications or indications in relation to the principles and rules of conduct established in this Code, he can contact to resolve his doubts:

to your direct supervisor for matters relating to your area of responsibility; to personnel management for questions and doubts relating to laws or internal regulations of the Company; to the financial director for doubts relating to financial aspects; to the Directors for aspects relating to corporate policies and practices.

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If a person required to comply with this Code of Ethics wishes to contact a person external to his own company unit, for any question on possible violations of the law as well as the principles and rules of conduct established in this Code, he can contact the Board of Statutory Auditors.

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