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GMDE logo

Code of Ethics

Collection of conduct principles

Adopted by the Ordinary Shareholders’ Meeting
on June 7, 2019

- PREAMBLE -

GMDE S.r.l. is a company operating in the fields of graphics, trade, technical assistance, repair, assembly, maintenance of software and hardware, research, consultancy, design, and installation of data and image processing systems, as well as agency and business procurement for software and hardware products. Its activities are guided by principles of integrity and fairness. These principles are a key factor in the company’s operations, and therefore the need for a Code of Ethics has arisen. This Code, as a set of principles and guidelines, is intended to guide the activities of GMDE S.r.l., directing the behavior not only of its employees but also of all those who interact with the company.

This Code of Ethics is a fundamental component of the Organization, Management, and Control Model (Corporate Compliance). In drafting it, the Guidelines developed by Confindustria have been considered, which allow the creation of Organization, Management, and Control Models aimed at preventing the offenses outlined in Legislative Decree no. 231 of June 8, 2001, concerning the administrative liability of companies.

The drafting of this Code of Ethics also took into account the Ten Principles adopted by the United Nations Global Compact, inspired by the Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, and the United Nations Convention Against Corruption.

* * * *

CHAPTER I

- GENERAL PROVISIONS -

  1. Recipients

The principles of this Code of Ethics bind the conduct of all those holding positions of representation, administration, or management in the Company, as well as those exercising control over GMDE S.r.l., all employees without exception, collaborators, and anyone else who engages with the company, directly or indirectly, permanently or temporarily, or collaborates in pursuing its corporate mission (hereinafter, the “Recipients”).

All of the above individuals are, therefore, the custodians of the Code, and in carrying out their activities they must adhere to the principles of impartiality, fairness, integrity, and transparency, always in compliance with the “legal provisions.” Legal provisions include all legislative or regulatory norms affecting the Company’s activities.

CHAPTER II

- ETHICAL PRINCIPLES -

The Company accepts and adheres to the following ethical principles (hereinafter, the “Principles”):

Recipients, in their work and professional activities for the Company, must align their conduct with the above Principles. Behaviors contrary to these Principles can never be justified by the belief that one is acting in the interest or for the benefit of GMDE S.r.l.