Code of conduct

Infordata Sistemi S.r.l. Società Benefit

This is a translation of the Italian Codice di Condotta. In case of any discrepancy, the Italian version prevails.

1. Purpose and scope

This Code of Conduct complements and implements the principles of the Code of Ethics of Infordata Sistemi S.r.l. Società Benefit, turning them into concrete rules of behaviour that bind everyone they apply to.

The Code applies to all employees, collaborators, interns, consultants, suppliers and business partners acting on behalf of, or in relation to, Infordata.

2. Colleagues and the working environment

2.1 Everyone is required to behave respectfully, cooperatively and without discrimination towards colleagues, regardless of role, gender, age, origin, sexual orientation, religion or disability.

2.2 All forms of harassment, intimidation, mobbing and bullying are prohibited, whether in person or through digital tools.

2.3 Infordata promotes an inclusive and safe working environment oriented towards people’s wellbeing, consistently with its status as a Società Benefit.

3. Customers and suppliers

3.1 Business relationships are conducted with fairness, transparency and good faith. Any form of corruption, whether active or passive, is prohibited.

3.2 Suppliers are selected on objective criteria of quality, reliability, sustainability and economic competitiveness, with equal opportunity respected.

3.3 It is prohibited to accept or offer gifts, hospitality or benefits of significant value that may influence, or appear to influence, business decisions. Gifts of modest value, in line with ordinary business courtesy, are permitted.

4. Use of company resources and IT systems

4.1 Company resources, including IT equipment, software, network access and confidential information, must be used exclusively for work purposes or otherwise in a manner compatible with the company’s needs.

4.2 Installing unauthorised software, using company resources for unlawful purposes, or accessing systems and data without authorisation is prohibited.

4.3 Access credentials are personal and non-transferable. Each user is responsible for safeguarding their own credentials.

5. Confidentiality and intellectual property

5.1 All company information — technical, commercial and organisational — learned in the course of work is to be treated as confidential and may not be disclosed to third parties without authorisation.

5.2 Software, documents, designs and solutions developed in the course of work are the exclusive property of Infordata, unless otherwise agreed in writing.

5.3 The duty of confidentiality continues after the employment or collaboration relationship ends.

6. Conflicts of interest

6.1 Everyone the Code applies to must avoid situations in which personal interests may conflict, even potentially, with the company’s interests.

6.2 Any potential conflict of interest must be reported promptly to one’s manager and to the Management.

7. Health, safety and the environment

7.1 Infordata ensures compliance with the health and safety legislation in force (Italian Legislative Decree 81/2008) and is committed to the continuous improvement of safety conditions.

7.2 Consistently with its objectives as a Società Benefit, Infordata promotes sustainable practices to reduce the environmental impact of its activities, favouring digital solutions, reduced energy consumption and responsible waste management.

8. Sustainability and social impact

8.1 Infordata factors environmental, social and governance (ESG) impacts into its strategic and operational decisions, in line with its mission as a Società Benefit.

8.2 Taking part in European research and innovation projects, and working with local bodies and communities, are an integral part of Infordata’s commitment to the common benefit.

9. Reporting and whistleblowing

9.1 Anyone who becomes aware of conduct breaching this Code is required to report it through the channels set out in the company Whistleblowing Procedure, available at: https://www.infordata.pro/whistleblowing-anonymous-reporting-channel/

9.2 The company guarantees that whistleblowers are protected from any form of retaliation, in accordance with Italian Legislative Decree 24/2023 and Directive (EU) 2019/1937.

10. Sanctions

10.1 Breaches of this Code of Conduct are assessed and sanctioned according to their seriousness, in accordance with the legislation in force and the applicable national collective agreement (CCNL), with impartiality and the right of defence guaranteed.

10.2 Breaches may lead to disciplinary measures up to termination of the employment or collaboration relationship, without prejudice to any civil or criminal liability.

11. Circulation and updates

11.1 This Code is communicated to everyone it applies to and made available on the company website. Infordata holds periodic training sessions to ensure it is understood and applied.

11.2 The Code is subject to periodic review and may be updated by the Management at any time.