1. With this Code of Ethics, Sis.Ter S.r.l. conforms to the principles of honesty, legitimacy, loyalty, fairness and transparency in the performance of its activities. In addition, the company has embarked on the path of transformation into a ‘Benefit Company’.
  2. Relations with third parties (customers, suppliers, external collaborators, partners, competitors, media, market, national and international civil and economic environment) are marked by loyalty and fairness, in the protection of the company’s interests. Equal loyalty and fairness can likewise be demanded from third parties.
  3. Sis.Ter S.r.l. considers respect for the environment a primary value of its economic activity and, therefore, orients its strategic choices in such a way as to respond to the principles of sustainable development; it promotes, in this sense, the environmental awareness of directors, employees, collaborators and third parties who come into contact with the company.
  4. Sis.Ter S.r.l. considers the creation of value for the generality of its shareholders as its primary objective. Each director, employee and collaborator must direct his or her actions toward the pursuit of this goal.
  5. Sis.Ter S.r.l. believes that human resources are an essential corporate asset, the development of which is a key factor in the achievement of set goals. The professionalism and dedication of employees are core values for the achievement of company goals.
  6. Sis.Ter S.r.l. is committed to developing the skills, stimulating the abilities and potential of its employees so that they find full realization in the achievement of goals.
  7. Sis.Ter S.r.l. offers equal employment opportunities to all employees on the basis of specific professional qualifications and performance capabilities, without discrimination. Proper personnel management is the ethical duty of all those with responsibility for them.
  8. Sis.Ter S.r.l. does not allow behavior that has discriminatory content and respects differences in religion, racial or ethnic origins, nationality, age, sex, political and trade union opinions, sexual orientation, health status, and generally any intimate characteristic of the human person.
  9. Sis.Ter S.r.l. puts in place all necessary measures to avoid any relationship with associations with the purpose of terrorism or aimed at the subversion of the democratic order.
  10. The company’s directors, employees and all collaborators, as recipients of this Code of Ethics, are required to abide by these principles, permeating their daily business conduct and turning them into a tool of assurance and reliability for the benefit of the general interests of the company and the country.
  11. All those (service providers, consultants, etc.) who, in various capacities, collaborate with Esa Sis.Ter S.r.l. are required, in their relations with the company itself, to comply with the rules of this Code of Ethics insofar as they are applicable to them.
  12. The rules contained in this Code of Ethics supplement the behavior that directors, employees and all collaborators are required to observe, also in accordance with the rules of ordinary diligence to which the employee is bound, governed by the Civil Code on labor relations (Articles 2104 and 2105 Civil Code).


Individuals in top positions, such as directors or individuals with management functions of the entire company, individuals who de facto manage or control the company, and individuals subject to the management or control of individuals in top positions (employees or collaborators), as identified by Art. 5, paragraph 1, of Legislative Decree. n. 231/01, must not violate the fundamental principles that govern proper conduct such as honesty and integrity in the pursuit of personal profit and/or the profit of Sis.Ter S.r.l.

In particular, members of the board of directors are required to be guided by the principles of the Code of Ethics when setting goals, proposing investments and implementing projects, and in any decision or action related to the management of the company. Managers, in the concrete implementation of management activities should be inspired by the same principles, both within the company, thus strengthening cohesion and the spirit of mutual cooperation, and towards third parties who come into contact with Sis.Ter S.r.l.

The provisions of this Code of Ethics also apply to all other employees, collaborators and external consultants acting in the name and on behalf of Sis.Ter S.r.l., as well as to employees, collaborators and external consultants of the Company.

All individuals identified in this paragraph are hereinafter referred to as “the recipients.”

Recipients are required to comply with applicable laws and regulations, as well as internal company regulations by orienting their actions and conduct to the principles, objectives and commitments referred to in this Code. To this end, Sis.Ter S.r.l. is committed to making all process regulations and related operating rules available at all times and updating them constantly and promptly.


  1. All actions, operations and transactions performed or put in place for the benefit of Sis.Ter S.r.l. or in its interest must be inspired by the utmost fairness from the point of view of management, completeness and transparency of information, legitimacy in formal and substantive aspects, and clarity and truthfulness in accounting records, in accordance with current regulations and according to established procedures, and must be subject to audit.
  2. In order to make any decision that directly or indirectly is put in place in the interest of Sis.Ter S.r.l. or for its benefit, the recipients assess all ethical and legal issues related to the decision in question and analyze all risk aspects and request, where deemed necessary assistance from those directly responsible.
  3. Recipients shall refrain from engaging in or attempting to engage in conduct that could constitute one or more “predicate” offenses under Leg. 231/01; in this regard, the need to refer to the most updated version of Leg. 231/01, given the constant introduction of new offenses.

In the event that these provisions are disregarded, Sis.Ter S.r.l. may take the sanctioning measures, provided for in the Chapter “Sanctions” of this Code, against the recipients who are found to have behaved illegally and in non-compliance with the rules of the code and the provisions in force.


  1. If recipients become aware of illegal or ethically improper situations or conduct that, even potentially, integrates the extremes of an illegal or improper activity carried out, directly or indirectly, for the benefit or in the interest of Sis.Ter S.r.l., they shall promptly inform the head of internal audit in writing for reporting to the Supervisory Board, even without following the established hierarchical order. Reports received are treated with the utmost confidentiality while maintaining, in all cases, confidentiality about the identity of the reporter.
  1. The above-mentioned reports are promptly verified by the Supervisory Board in ways that ensure the anonymity of the reporting party. Failure to comply with the duty to inform under consideration will be sanctioned by Sis.Ter S.r.l. in the manner provided in the Chapter “Sanctions”.
  1. Relations among employees, at all levels, are marked by criteria and behavior of fairness, loyalty and mutual respect. Thus, the misuse of disclosures or complaints for retaliatory purposes is sanctioned.


Recipients, in accordance with current regulations, operate in a manner consistent with the law and professional ethics. In particular, they shall not abuse their position or powers to compel or induce anyone (who has benefited or may benefit from decisions or activities inherent to the office held) to give or promise unduly to them or a third party – or to them or a third party on behalf of Sis.Ter S.r.l. – money, gifts or other benefits, except in the case of gifts for use of modest value.


A conflict of interest occurs in the case of potential interference of personal interests with an employee’s ability to exercise objective judgment or perform his or her work in the interests of Sis.Ter S.r.l. Recipients avoid conflicts of interest as well as avoid situations of potential incompatibility.

Without prejudice to any legislative and contractual provisions, the recipients shall avoid all situations in which they might find themselves, even potentially, in conflict of interest with the latter; they shall disclose, in their respective operating environments, any interest they have, on their own behalf or on behalf of third parties, in a given operation of the company itself, notifying the manager who will inform the Supervisory Board; and they shall refrain from procuring personal advantages in the performance of their respective activities.


Sis.Ter S.r.l. protects the principle of confidentiality of information, data and news, even of third parties, pertaining to its activities and ensures that it is also respected and safeguarded by its collaborators.

In order to safeguard know-how, the recipients, subject to any legislative and contractual provisions, shall not disclose information that is not in the public domain of which they have become aware and shall use it only for purposes strictly related to the performance of their duties.

In this regard each contributor:

  1. acquires and processes only those data that are necessary and directly related to its functions and stores them in such a way as to prevent their disclosure to third parties;
  2. communicates and discloses data within the framework of established procedures or with the authorization of the person delegated to do so;
  3. determines the confidential and confidential nature of the information in accordance with the requirements of the relevant procedures, including computer procedures.

Sis.Ter S.r.l. binds third parties to whom it intends to communicate confidential information to comply with specific confidentiality covenants.


Institutional relations with the Public Administration are reserved exclusively for the competent and delegated corporate functions, which must operate in accordance with principles of integrity, independence and fairness, in a manner consistent with the law and ethics.

It is forbidden to offer, promise or execute payments, compensation and/or gifts of any kind for the purpose of inducing, facilitating or remunerating the performance of an official act or an act contrary to official duties by a public official or a person in charge of a public service.


Sis.Ter S.r.l. operates with full respect for human dignity. To this end, it is committed to ensuring a healthy and safe working environment with respect for the environment and in compliance with all regulations to protect worker safety and the environment.

Each recipient shall pay careful attention to the prevention of hazards in order to avoid accidents and personal injury. Observes all health and safety regulations as well as practices relevant to their work. Takes all necessary precautions to protect himself and his co-workers, including appropriate clothing, protective equipment, and immediate reporting of accidents, personal injuries, and unsafe practices at his premises to the direct supervisor and/or the prevention and protection service.

In addition, Sis.Ter S.r.l. is committed to avoiding any negative impact on the environment and the communities in which it operates, promoting ecological sustainability, right from its corporate purpose, in all its activities, while respecting the rights of future generations.

Sis.Ter S.r.l. constantly evaluates the environmental consequences of its activities, with continuous attention to ensure that they are carried out not only in accordance with the relevant national and international directives, but also with respect for the environment and public health.


Recipients are sanctioned by the company if they perform acts or omissions unequivocally directed at violating the rules of conduct set forth in this Code of Ethics, even if the intended event does not occur.

The Competent Body, depending on the seriousness of the illegal activity carried out by the person found to be involved in one of the illegal activities envisaged in this Code of Ethics, will take the appropriate measures, regardless of whether criminal prosecution is carried out by the judicial authorities.

In imposing sanctions, the competent body will not fail to take into account: a. Of the circumstances under which the misconduct took place;

  1. Of the type of wrongdoing perpetrated;
  2. Of the seriousness of the conduct engaged in;
  3. Of whether the behaviors solely constitute an attempted violation;
  4. Of the subject’s recidivism.

In these cases, the Company is entitled to any damages suffered as a result of the unlawful conduct carried out.

Procedures for contesting violations of this Code and imposing consequent sanctions will take place in full compliance with the provisions of Art. 7 of the law of May 20, 1970, no. 300 and as established by labor agreements and contracts, where applicable.