Code of Conduct
De Vellis Traslochi e Trasporti S.r.l. is renowned for its high ethical standards in conducting business. It is important that we all strive to uphold this tradition of integrity.
All employees of the company are required to maintain and protect our excellent reputation. We demand that every employee strictly adhere to the company's business ethics principles and maintain behavior consistent with them. No employee in a managerial position has the authority to instruct a subordinate to violate the company's ethical guidelines.
Each employee must comply with applicable laws, bearing in mind that our business ethics standards go beyond mere legal compliance. No regulation can replace the exercise of simple morality, common decency, high ethical principles, and respect for the law by each person representing our company. If an employee is uncertain about the appropriateness of a particular action, they should ask themselves the following question: if this action were made public, would the employee and the company feel comfortable from a moral, ethical, and legal standpoint? If the answer is "yes," the action is probably consistent with the company's philosophy. If the answer is "no," the action should be reviewed with a supervisor before proceeding.
The Company encourages internal communication and dialogue and promotes positive examples, believing this effectively contributes to spreading a culture of excellence as a corporate asset and upholding ethical standards of conduct.
Therefore, if you become aware of situations that are or appear to be contrary to the principles of the code of conduct, or if you receive instructions from a superior to act in a way that you believe is contrary to these principles, you are requested to report it to a superior or a manager.
Upon receiving the report, the company will conduct an investigation and, if a violation is found, take the necessary actions. The company is committed to protecting employees who responsibly report potential violations of the code of conduct from retaliation and reprisals. Conversely, an employee who participates in or conceals a violation of the code of conduct risks disciplinary measures that may include, in some cases, dismissal.
Every action taken by an employee of De Vellis Servizi Globali S.r.l. in the performance of their duties aims to meet a client's needs within the boundaries defined by the code of conduct. The company's success and job security depend on our ability to adequately meet our clients' needs.
Every employee is required to exercise and promote high professional standards in performing their duties and in their relationships with colleagues, suppliers, clients, and anyone associated with the company.
Consistent with these principles, employees are expected to conduct their relationships with courtesy, dignity, and respect. This is especially true for those holding significant corporate positions who can influence job security, remuneration, promotion, and the career of other employees. Such responsibilities include, among other things, the duty to avoid discriminatory behavior and any offensive behavior regarding race, religion, creed, or ethnicity of others.
We all value the ethnic and cultural diversity present in our company. We encourage contributions from all our collaborators and aim to develop and utilize their capabilities, creativity, and energy to the fullest, fostering a work environment that allows each person to reach their maximum potential.
The Company considers honesty an essential value in managing relationships at all levels and values employee fairness in relationships with colleagues and in carrying out internal and external business activities.
All reports and responses provided internally or externally (client, supplier, financial institutions, state agencies of any kind, businesses, and/or individuals who need or have the right to receive such information) must be truthful, accurate, and not misleading, avoiding the inappropriate disclosure of company data and information to external individuals or entities.
The Company relies on the accuracy of its data to make important business decisions, provide and receive payments, and supply data and reports to state agencies and other bodies. Therefore, it is essential that all acts, data, and records are accurate and complete. Employees are prohibited from making false or misleading entries in the company's, client's, or third party's records or reports.
We sell our products and services based on the advantages they offer. We treat competitors with the same respect we expect to be treated with by them. We will not engage in illegal agreements or activities with competitors or third parties.
Employees must not use improper or illegal methods to obtain data and information about competitors. We do not encourage current or future employees to disclose confidential data and information they may have obtained during employment with other companies.
We are committed to creating safe working conditions for our employees, ensuring the safe use and management of our services, and complying with environmental protection laws. Every employee has the duty to promote and pursue these objectives in the performance of their duties.
In the performance of their duties, employees may have access to confidential data and information regarding other employees, such as information on job applications, pay slips, and other confidential information. All employees are required to handle such data and information with the utmost confidentiality, using it only for the intended purposes and disclosing it only to those who "need to know."
The company's tools, equipment, facilities, and inventory, as well as know-how, technology, market information, and operational plans, are valuable assets. Every employee has the duty to preserve and protect the company's assets and confidential data, ensuring they are not misused or made available to third parties in any way that could harm the company's interests.
Every employee of De Vellis Servizi Globali S.r.l. commits to not prioritizing their personal interests over those of the Company. Even the appearance of a conflict of interest can damage an employee's or the Company's reputation. Therefore, the Company recommends that each employee discuss any potential conflict of interest with their supervisor. Many conflicts of interest can be resolved acceptably by both parties involved.
Given the multitude of circumstances that could give rise to potential conflicts of interest or appear as such, the following are provided as indicative and non-exhaustive examples:
- The employee induces the Company to do business with their relatives or friends.
- The employee uses non-public information regarding the Company, its clients, or its suppliers for their benefit or that of relatives or friends.
- The employee has a financial stake or a position of control in a competitor's, supplier's, or client's company.
- The employee receives a loan, guarantee, or other personal benefit from third parties due to their corporate position with the Company.
Employees have the duty to promote the Company's interests whenever possible. Employees must not compete, or prepare to compete, with the Company during the term of their employment contract. Employees are not authorized to exploit for personal gain opportunities they become aware of through the use of the Company's assets, information, or position unless this has been previously and expressly authorized by the appropriate executives.
Employees of De Vellis Servizi Globali S.r.l. are authorized to entertain clients, suppliers, and others and to be entertained by them, provided this is done according to customs and in compliance with the Company's internal provisions.
The Company requires its employees to strictly observe anti-corruption laws in the United States and similar laws in other countries. De Vellis Servizi Globali S.r.l. rejects illicit practices and prohibits its employees from giving or offering money, goods, and/or other benefits to ensure favorable treatment for the Company from clients, suppliers, holders of national or foreign public offices, or third parties. This conduct also applies when intermediaries are used to make such payments. If an employee finds themselves in a situation where payments that may not be due are expected, they must consult their superior and the company's legal department before acting, as the laws on these matters are very complex.
Accepting gifts from suppliers, clients, or third parties with business relationships with the company could constitute a conflict of interest or appear improper. Therefore, employees of De Vellis Servizi Globali S.r.l. are required to refuse any cash payment offered by individuals with business relationships with the Company. Employees may accept reasonable, non-cash gifts of symbolic or nominal value from companies or individuals who do business or may do business with the Company, provided they are not intended and cannot be interpreted as bribes, means of corruption, or other forms of undue compensation for the recipient.
It is company policy to observe the laws governing corporate conduct. Each employee has the duty to familiarize themselves with the principles and rules concerning the performance of their duties, assist the Company in complying with the laws, and seek their superior's advice whenever they have legal uncertainties.
Our code of conduct applies to all employees, including managers. We are confident that we can count on all employees and managers to maintain the excellent reputation our company enjoys.
De Vellis Servizi Globali S.r.l.
Ennio De Vellis
Sole Director