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Compliance and Organizational Model

In carrying out its business activities, TeamSystem S.p.A. is aware that professional reputation is a key factor for the success of its growth and accordingly intends to embrace the values of fairness, transparency, correctness and compliance with applicable laws, rejecting any form of illegality or conduct contrary to these principles.

For this reason, the Company's Board of Directors intended to adopt an Organizational, Management and Control Model with the aim of preventing the risk of potential criminality or, in any case, conduct that does not comply with the regulations in force (the 'Organizational Model') and a Code of Conduct with the aim of clearly defining the lines of ethical behavior required of all its recipients (the 'Code of Ethics').

The Code of Ethics and the Organizational Model complete and integrate the path to transparency in business relations and in the fight against corruption already started by the Company with its adoption of the Anti-Corruption Code of Conduct, approved in April 2015 and recently updated in order to bring it into line with the U.S. Foreign Corrupt Practices Act of 1977 (the ‘Anti-Corruption Code’).

ETHICAL CODE

The TeamSystem Group believes that compliance with ethical rules and transparency in the conduct of business is a necessary condition, as well as a competitive advantage, for pursuing and achieving its objectives.

To this end, TeamSystem promotes the creation of an environment characterized by a strong sense of ethical integrity, in the firm belief that this will contribute decisively to the effectiveness of policies and control systems, influencing behavior that could escape even the most sophisticated supervisory mechanism. 

TeamSystem has accordingly deemed it appropriate and necessary to adopt and issue a Code of Ethics that sets out the values to which the conduct of all those who, at various levels of responsibility, contribute by their work to its activities. All our consultants, business partners, suppliers and/or external employees, must be guided by those values.

The principal values are:

  • moral integrity, personal honesty and fairness in internal and external relations;
  • transparency with shareholders, related stakeholders and the market;
  • respect for employees and a commitment to enhance their professional skills;
  • social commitment;
  • health, safety and environmental protection;

and, more generally, 

  • the rejection of any conduct that, although aimed at achieving a result consistent with TeamSystem's interest, has aspects that are not compatible with the law and the rules of conduct in force within the Company.
 

>> DOWNLOAD THE CODE OF ETHICS <<

ANTI-CORRUPTION CODE OF CONDUCT

TeamSystem adheres to and promotes policies consistent with laws and legal standards for the prevention of corruption and transparency in business dealings (hereinafter also Anti-Corruption Laws), nationally and internationally.

The Anti-Corruption Laws define as illegal, for TeamSystem's staff, Business Partners and anyone working for or on behalf of the Company, to make any promise, offer, payment or acceptance, directly or indirectly, of money or other benefits, in order to obtain or retain business and secure an unfair advantage through conduct by public and private counterparties contrary to their professional duties and/or office.

In particular, in order to prevent conduct prohibited by Anti-Corruption Laws, the Company has decided to adopt a specific Anti-Corruption Code of Conduct, which forms part of a broader regulatory compliance program adopted by the Company. The Anti-Corruption Code of Conduct, accordingly, aims to provide all staff with the rules to be followed to ensure compliance with Anti-Corruption Laws.

 

  >> DOWNLOAD THE ANTI-CORRUPTION CODE <<

 

MODEL 231/2001

With the adoption of the Organization, Management and Control Model under Legislative Decree 231 of 8 June 2001 (the "Organizational Model") by resolution of the Board of Directors on 16 March 2017, TeamSystem S.p.A. will aim at the following objectives:

  • to ensure that the Company's activities and processes are carried out in compliance with the ethical values to which our Company adheres, as detailed in the Code of Ethics, which forms the fundamental 'Charter of Values' that must inspire all Company activities;
  • to condemn all forms of unlawful conduct by all those who work in the name, on behalf of and in the interest of the Company, insofar as they are contrary not only to the provisions of the law, but also to the ethical principles adopted by the Company and with which the Company intends to comply;
  • to create in all its recipients the awareness that breach of the provisions of the Organizational Model may constitute an offence punishable by penal and administrative sanctions, which may be imposed not only on the individual, but also on the Company;
  • to guarantee that the Company, by means of control and monitoring of corporate activities in areas of activity at risk, has a concrete and effective possibility of timely intervention to prevent offences;

To guarantee the constant and effective implementation of the Organizational Model, the Code of Ethics and the Anti-Corruption Code, a disciplinary system is in place to sanction any breaches of the Organizational Model, the Code of Ethics and the respective provisions, both by Company personnel and by its consultants, other employees or business partners.

The Company has also set up a Supervisory Board with the task of overseeing the operation of and compliance with the Organizational Model and the Code of Ethics.

All recipients of the Organizational Model are required to report to the Supervisory Board any breaches of the provisions of the Organizational Model, the Code of Ethics or the Anti-Corruption Code, of which they become aware.

Reports to the Supervisory Board should be sent to:

organismodivigilanza@teamsystem.com

Reports may also be mailed to the Supervisory Board at the Company's registered office, at the following address:

TeamSystem S.p.A.

Via Sandro Pertini 88, 61121 Pesaro (PU)

For the attention of the Supervisory Board

Mark the envelope PERSONALE E STRETTAMENTE RISERVATO – DA NON APRIRE' (PERSONAL AND STRICTLY CONFIDENTIAL - DO NOT OPEN).

 

DOWNLOAD FORM 231/2001

THE MANAGEMENT OF REPORTS:
WHISTLEBLOWING

Our commitment

TeamSystem S.p.A (the ""Company""), promotes an ethical, transparent and responsible work environment. Therefore, in accordance with new legislation on Whistleblowing (""Legislative Decree 24/2023"" or also the ""Whistleblowing Decree""), the Company offers all employees and other interested parties identified by the Whistleblowing Decree (specifically, in addition to employees: former employees, self-employed workers, external staff, volunteers and trainees, shareholders and persons with administrative, management, supervisory, control or representation functions, workers not yet employed and workers during the trial period) the possibility of reporting, even anonymously, unlawful conduct occurring within the work-related context that violates the Organization, Management and Control Model pursuant to Legislative Decree no. 231/2001 of the Company, the Code of Ethics and the Anti-Bribery Code as well as, where the requirements of the Whistleblowing Decree are met, European Union law or national legislation identified by Legislative Decree 24/2023.

Platform

In compliance with the legislation on whistleblowing, the Company has adopted a suitable whistleblowing management system by providing a specific platform (""Whistleblowing Platform"") to guarantee the protection of the whistleblower at every stage of the reporting process and to ensure the utmost confidentiality of his/her identity, the facts subject to reporting, as well as the identity of the reported subject.

The Whistleblowing Platform is available at the following link: TeamSystem Speak UP!

Each report will be carefully evaluated by a committee that has been specifically set up - the Whistleblowing Committee, which will handle the report in compliance with current regulatory provisions, initiating, if necessary, appropriate investigations.

Finally, we remind you that the Whistleblowing Decree guarantees legal protection to whistleblowers who act in good faith, prohibiting retaliatory or discriminatory acts, direct or indirect, against whistleblowers for reasons directly or indirectly related to the whistleblowing. On the contrary, the intentional defamation of third parties through false or malicious reports may result in the activation of the disciplinary system against the reporting employee as well as any legal consequences.