Compliance

Etichal 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-Corrumption 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 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.

ISO 9001 and ISO 14001 Certification

TeamSystem considers compliance with certification standards a strategic commitment, on which to base and consolidate objectives, shared values and processes aimed at the continuous improvement of the company and at the growth of Customer satisfaction.
Over time, the Quality System compliant with the 9001 standard has allowed to:

• define and determine our best practices with the full involvement of all stakeholders and adopt an organisational model capable of ensuring effective and efficient process control and a constant level of performance quality;
• build a shared and widespread corporate culture based on the principle of integrity, responsibility and awareness of the Organisation's values.

Quality, in its broadest sense, must be considered a topic of primary importance and an integral part of every work activity; for this reason, in order to ensure achieving the related objectives, TeamSystem has implemented a specific organisation. 
The focus on competitiveness and Customer satisfaction is a primary objective for everyone within the scope of their respective responsibilities, but today it cannot ignore integrating corporate strategies with the objectives and conduct inspired by principles of sustainability and environmental responsibility, demonstrating this commitment by implementing a Management System that complies with the ISO 14001 standard.

In harmony with the European strategy outlined in the UN Agenda 2030 and by the institutions, TeamSystem intends to base its development model on an organisational structure, values, conduct and objectives with fully positive and sustainable impacts on the environment and the ecological transition process, implementing the mitigation measures identified.
Through its Environmental Management System, TeamSystem intends to adopt a governance system, based on principles of due diligence and accountability and focused on its responsibilities also with respect to the various stakeholders, in order to transparently define and share its commitments and improvement objectives, compliance obligations, the monitoring of its environmental performance.

DOWNLOAD ISO 9001 CERTIFICATION

DOWNLOAD ISO 14001 CERTIFICATION

ISO 27001, ISO 27017, ISO 27018 Certification, SPID Accreditation and eIDAS Regulation

TeamSystem considers compliance with the ISO/IEC 27001, ISO/IEC 27017 and ISO/IEC 27018 certification standards a strategic commitment on which to base processes aimed at the continuous improvement of the company and at the growth of Customer and stakeholder satisfaction.

The information security management system compliant with the ISO/IEC 27001 standard and its extensions ISO/IEC 27017 and ISO/IEC 27018 allows:

1. Systematically assessing information security risks, taking into consideration the impact of threats and vulnerabilities.
2. Implementing controls to address corporate and architectural security risks with a focus on the security of Personally Identifiable Information (PII) in the public cloud.
3. Adopting suitable management procedures to periodically check the compliance of the information security controls.

TeamSystem services that fall within the scope of the ISO/IEC 27001:2022, ISO/IEC 27017:2015, ISO/IEC 27018:2019 standards are available in the attached ISO certificate.

TeamSystem has also obtained two additional accreditations: as Identity Provider for issuing the SPID digital identity and for the European eIDAS regulation. Both certificates can be consulted on this page.

DOWNLOAD THE ISO 27001, ISO 27017, ISO 27018 CERTIFICATION

DOWNLOAD THE eIDAS CERTIFICATION

DOWNLOAD THE SPID CERTIFICATION