CODE OF ETHICS

TITLE I

General rules

Art. 1 – Definitions

In this Code the meanings are as follows: “SeS” or “Studio”: Salvini and Associates – Tax law firm founded by F. Gallo, including Associates and Collaborators. Statute: the Statute of SeS. Code of Ethics: statement of ethical principles and values of SeS and consequent conduct criteria to which the Addressees are bound. Associates: the members of the Firm. Collaborators: all the people who collaborate with SeS, that is professionals, employees, trainees and those who, with a certificate of accomplished practice, are waiting to carry out the State exam to obtain the qualification, interns. Recipients: Associates, Collaborators, and any other person who may act in the name and on behalf of SeS, as they are required to comply with this Code of Ethics. Statute: the Statute of the Salvini and Soci Association. Assembly: the Assembly of SeS, as regulated by art. 12 of the Statute. 

Art. 2 – Principles
  1. The Code of Ethics affirms the principles and values that inspire the conduct of the professional activity of the Associates, of the Collaborators and in general of the Recipients.
  2. The Recipients observe the highest standards of ethical conduct. In carrying out their duties they operate with honesty, decorum, discretion, correctness, transparency and loyalty, conforming to the fundamental values referred to in Title II, in the knowledge that compliance with the Code of Ethics is an essential part of one’s work and professional performance.
  3. Recipients are also aware of the fact that observance of the Code of Ethics is an obligation of fundamental importance for the professionalism, quality, reliability and reputation of SeS.
  4. The provisions of the Code of Ethics integrate the rules of conduct and ethics that the Recipients are required to observe based on the discipline of their professional activity, regulations in force, labour contracts, internal procedures, as well as behaviour codes that SeS may subscribe to or issue internally.
  5. Behaviours that, while being implemented in formal compliance with the provisions of this Code, are in violation of the substance and in any case lead to results incompatible with the provisions of this Code are prohibited.
  6. I In no event the pursuit of the interest of SeS or the achievement of an advantage for the same firm may justify the adoption of unlawful or illegitimate behaviour or in any case contrary to the principles contained in this Code.
  7. The Code of Ethics will prevail over any provision in the case in which a provision of the Code of Ethics comes into conflict with provisions set forth in the procedures or internal regulations.
  8. SeS intends to promote and communicate its guiding values externally and for this reason the Code of Ethics is published online in the website www.salviniesoci.it and displayed in paper format in the firm.

TITLE II

Basic values and professional ethics

Art. 3 – Professionalism and competence
  1. Associates and Collaborators have the obligation of continuous professional updating and training, with the aim of providing an adequate professional contribution with respect to the task assigned and in the area of competence. Consequently they are required not to accept assignments that they know they cannot carry out with the necessary competence or for which they are unable to ensure complete and adequate advice and assistance.
  2. SeS promotes the growth and professional preparation of Collaborators, through participation in courses, conferences, publications and updates on regulatory changes.
Art. 4 – Deontology

The Code of Ethics integrates the Code of Professional Conduct as well as, for Associates and Collaborators enrolled in other professional associations, that of the Register of membership and is also based on non-legal rules. It is also aimed at the moral and professional sensitivity of individuals. All participants in the organisation and operation of SeS have the moral responsibility for the dissemination and application of the values expressed by the Code of Ethics, with reference to the functions assigned to them.

Art. 5 – Quality

 SeS directs its business to the highest quality standards for the purpose of customer satisfaction. The main objective that Associates and Collaborators must pursue is to create quality relationships with customers. In this respect, the relational quality, in assistance and consultancy activities, means adopting high reliability, availability, timeliness, preparation and transparency behaviours, combined with the use of understanding and interaction skills.

Art. 6 – Professional objectivity
  1. Associates and Collaborators act in respect of the facts ascertained with professional work, reject partisan attitudes, conditionings and influences that can alter the facts for external interests.
  2. Objectivity implies that Associates and Collaborators make the advantages and disadvantages of the technical solutions proposed known to the recipient of the professional services.
Art. 7 – Honesty
  1. Recipients must carry out their activities with honesty and integrity, refraining from unlawful conduct and engaging in corruption practices, illegitimate favours, collusive behaviour and solicitations of personal advantages. In particular, it is forbidden to pay or offer, directly or indirectly, payments, utilities or other benefits to organisations or companies, public officials and public or private employees, to influence or compensate for obtaining assignments or actions in favour of the Firm.
  2. Acts of courtesy (made or received), such as gifts or forms of hospitality, are allowed only if of low value and in any case such as not to compromise the integrity or reputation of one of the parties and so that they cannot be interpreted as aimed at acquiring advantages improperly.
Art. 8 – Secrecy and confidentiality
  1. Recipients are required to respect the obligation of professional secrecy in compliance with the laws in force and those provided for the processing of personal data.
  3. Recipients are required to maintain the utmost confidentiality of the information of which they become aware and undertake not to disclose by any means information that is not in the public domain relating to customers and to the tasks entrusted to the Firm, unless written authorisation is given by the clients themselves.
Art. 9 – Compliance
  1. Recipients do not use confidential information to which they have access in order to carry out operations of any nature, directly or indirectly, at their own risk and for their own account or at risk or on behalf of third parties.
  2. Recipients observe the regulations in force concerning money laundering and insider trading.
Art. 10 – Correctness and loyalty

Associates and Collaborators must inspire their professional activity to the full and substantial respect of the principle of correctness and loyalty towards other Associates and Collaborators, the client and third parties.

Art. 11 – Respect for the person
  1. SeS guarantees its Collaborators and Employees the right to work conditions that respect the dignity of the person and of the contract of employment or collaboration.
  2. SeS prevents and contrasts acts of psychological violence or discriminatory or harmful attitudes or behaviours of the person, of his/her beliefs or conditions, mobbing, harassment and any form of discrimination on grounds related to gender, sexual orientation, ethnicity, health status, nationality, to political and union opinions, to religious beliefs.
Art. 12 – Conflict of interest
  1. In carrying out the collaboration, recipients pursue the objectives and general interests of SeS.
  2. Associates and Collaborators must inform without delay, taking into account the circumstances, of situations or activities in which they may have conflicts of interests with those of SeS (or if such interests are next to kin), and in any other case where there are important reasons of convenience.
  3. Recipients respect the decisions taken by the Assembly on the matter, pursuant to art. 12.6 of the Statute.
Art. 13 – Ethical principles of behaviour in internal relationships
  1. Associates and Collaborators must act loyally in internal relationships within SeS, according to good faith and with the utmost transparency, supporting the dissemination of all elements that can favour or hinder the exercise of the profession and its future development.
  2. Manifestations of respect and correctness are for example attention towards a colleague and compliance with the rules of respect, greeting, cordiality, refraining from initiatives that contribute to attracting a customer attended by others in the exclusive sphere, acknowledgement and valorisation of the skills and talents of other Collaborators, not damaging others for own interests and benefits. Behaviours characterised by personal interest, bitterness and conflictuality that violate or may suggest that the rules of the Code of Ethics or of the present Code of Ethics are violated must be avoided.
Art. 14 – Ethical principles of behaviour in external relations
  1. In the exercise of their activity, Associates and Collaborators must respect all the fundamental values of this Code. Members of the Firm are also required to use the utmost clarity in relations with the customer, or to simply illustrate the essential elements and the possible risks associated with the case that is assigned to them. The relationship with the customer is essentially based on trust and therefore Associates and Collaborators must adopt professional behaviours that demonstrate seriousness, availability, professionalism and respect towards the same client.
  2. Relations with Magistrates, public authorities and prosecutors of the other parties must be marked by dignity and respect for each other’s functions.
  3. The Firm does not grant, directly or indirectly, funding to political parties or organisations, their representatives or candidates. The possible participation of the Recipients in political parties or organisations – or the financing of the same – takes place in compliance with the applicable rules and is exclusively personal.
  4. In relations with the press and other media, particularly in the case of very important professional interventions, Associates and Collaborators must respect the obligation of confidentiality as foreseen by art. 8.
  5. The Firm manages the process of purchasing goods and services according to the criteria of reliability, cost and quality of the supplier, and considers the relationship with suppliers to be the starting point for activities to improve processes and services. In this context, relations with suppliers require actions consistent with the Code of Ethics.
Art. 15 – Protection of privacy
  1. SeS guarantees compliance with the regulations in force concerning privacy and undertakes to protect the confidentiality of all information of any nature or object which comes into its possession in the performance of its activity, avoiding any improper use or undue dissemination.
  2. Each Recipient is obliged to ensure maximum confidentiality of the information of Clients of which he/she becomes aware, as envisaged by art. 8.
  3. Any investigation on ideas, preferences, personal tastes and, in general, the private life of Collaborators, Recipients and customers is prohibited.