The purpose of this Code is to describe our standards of business ethics. It applies to all E. Laviosa  Group’s employees and others working with or for the Company. This Code addresses certain major concerns applicable to us all, even if it does not pretend to be fully exhaustive.

Compliance with the law 

We comply with the laws and regulations of Italy, Europe and the Countries in which we might find ourselves working.
We understand and adhere to the standards of business conduct relevant to our assignment, profession and position. We will not be prompted by any misguided sense of loyalty or desire for personal gain to violate applicable laws, company principles, policies or policy descriptions. 

Fair business conduct 

We conduct our business in a fair and ethical manner, promoting fair competition and protecting the interests of our customers and other stakeholders. Competition and anti-trust law promotes free enterprise and prohibits behaviour that restricts fair competition and applies to all business areas. It combats illegal practices such as price fixing, allocation of customers or markets, or any abuse of a dominant market position. E. Laviosa Group is committed to fair competition and does not tolerate violations of competition and anti-trust laws and regulations; employees are encouraged to report to management any concerns with regard to unethical conduct.

Financial offerings and/or gifts 

We do not offer or accept monetary benefits or gifts to achieve business advantages which we would not otherwise be entitled to. If we receive such offerings, we question why they are made and if anything is expected in return. We ensure that all offerings of any significance are disclosed and approved by our respective manager. 

Corruption and facilitation payments 

We have a zero tolerance policy towards bribery, which is the acceptance, offering, solicitation or promise of benefits, monetary or in kind, in order to gain business advantages to which we would otherwise not be entitled. Bribery is illegal worldwide and we are committed to comply with relevant laws prohibiting bribery.  
Facilitation payments are unofficial payments made to facilitate, secure or speed up performance of business transactions, duties or services, which one is otherwise entitled to. Such payments are not limited to monetary consideration, but may take other forms such as gifts or entertainment. E. Laviosa Group is committed to prevent the occurrence of bribery in all activities under our effective control. Any offering or accepting of bribes in any form to any person, whether private or public, direct or indirect, through third parties, is prohibited.  We recognize that facilitation payments are bribes, and as such we are committed to work to identify and eliminate them. E. Laviosa Group’s employees, or members of their families, must not allow gifts and hospitality to influence their objectivity and independence, or cause others to perceive an influence. At the same time, no E. Laviosa Group’s employee shall offer gifts or hospitality when it could affect, or be perceived to affect, the outcome of a business transaction

Working environment 

We behave with respect for the people with whom we work. Harassment, discrimination or other behaviour that may be perceived as threatening or degrading is not acceptable. We do not discriminate against others on the grounds of race, gender, sexual preference or any other grounds. 

Drugs and alcohol 

Possession or use of any substance prohibited by law is not tolerated while on duty or representing the E. Laviosa Group. Consumption of alcohol in the workplace is not allowed except where it is acceptable in moderate amounts and appropriate with the circumstances and applicable laws. 

Conflicts of interest 

We do not engage in activities that involve, or might appear to involve, a conflict between our personal interests and those of the company. Such conflicts of interest could compromise our ability to make correct business decisions. In cases of doubt, we will discuss the situation with our respective manager. 

External engagement 

We obtain approval from our respective manager before engaging in external business enterprises, statutory authorities or similar bodies which may have commercial relations to our company. When participating in an external activity, we will ensure that any opinions we express are in harmony with the company’s interests.

Confidential information and insider dealing 

We show great care before sharing confidential or business sensitive information with others. When appropriate we obtain a confidentiality agreement to protect our Group’s interests.