Governance

Honesty and Fairness
We operate in accordance with the highest ethical standards and with the laws and regulations in force in Italy and - where applicable - in other countries we operate in.

The pursuit of business interests or objectives can never justify conduct contrary to our principles of fairness, honesty and professionalism.

Conflicts of Interest
In our business activities, we avoid situations of conflict of interest, whether real or potential.

Free Competition
We recognise the principle of fair and free competition as a decisive factor for the growth and continuous improvement of the market and organisations.

Transparency and fairness in information
We are committed to providing complete, transparent and understandable information. Each and every operation and transaction is properly recorded, authorised, verifiable and legitimate.

Equality and Equity
We do our utmost to avoid discrimination based on age, racial and ethnic origin, nationality, political opinions, religious beliefs, sex, sexuality or the state of health of the subjects involved.

Enhancement of Human Resources
We guarantee a work environment aimed at enhancing the professionalism and skills of our resources, providing them with suitable training, professional updating and development tools.

Confidentiality
In accordance with current legal provisions, we guarantee the confidentiality of the information entrusted to us. Our staff are prohibited from using “confidential” information for purposes other than the performance of their job.

Health Protection
Regardless of the type of contractual relationship, we guarantee our employees working conditions that respect individual dignity, in safe and healthy working environments.

Environment
We are committed to environmental protection and ensuring the compatibility of our business activities with environmental requirements, in accordance with current legislation.

Tangible and intangible assets of the Company
The use of the Company's intellectual and tangible assets, including IT tools, must comply with the general rules and their intended use and in such a way as to protect their conservation and functionality, avoiding use that breaches law provisions.

We focus our business on satisfying and creating value for our customers.

Commercial negotiations – direct or indirect – business relations, contracts and our communications are inspired by the principles of honesty, professionalism and transparency and are based on maximum collaboration, with the aim of treating customers that are in the same conditions in a uniform way.

Customer satisfaction

We consider it essential to maintain high quality standards and maximise customer satisfaction. The internal procedures and IT technologies used support these aims, also through continuous monitoring of our customers.

Transparency
We provide our partners with all the information and documentation needed to support the decisions that concern us. We do not contemplate business relationships with third parties whose participation in criminal or manifestly unethical activities has been confirmed or is even just reasonably assumed.

Our goal is not to create false or inaccurate impressions or provide false or biased information. We do not tolerate or accept ambiguous behaviour that may lead the counterpart to have incorrect or exaggerated expectations in relation to the subject of the negotiation.

Competition
We compete with competitors through fair, ethical and law-abiding business conduct, ensuring fair treatment of customers, avoiding the application of prices and contractual conditions that have the sole purpose of excluding competitors from negotiations. We pledge not to enter into agreements aimed at restricting competition, nor to engage in conduct that may breach laws concerning competition.

Information about OCS S.P.A. or the OCS Group
If a competitor contacts a member of our staff, he/she will not provide such competitor with any information about prices, contractual conditions, costs, product marketing plans, production plans and/or any other information owned by OCS or which is confidential.

Relations with Suppliers and Partners
We are committed to dealing with our Partners and Suppliers on an equal footing and with mutual respect, recognising their role and the importance of a relationship based on mutual trust and transparency. The selection of Business Partners must be made based on clear, certain and non-discriminatory procedures, and on criteria related to the objective competitiveness of the services and products offered and their quality, also understood as full acceptance by the supplier of the ethical standards expressed in this Code.

The choice of suppliers is made on an objective and impartial basis, with the aim of providing our customers with the best conditions and solutions in both qualitative and economic terms. Before assigning activities to be carried out in the Company or in the production cycle of the same, under a works or services contract to third parties, the technical and professional suitability of such third parties is verified, implying compliance with the specific legal obligations in the field of occupational safety and health. Our decisions will not be influenced by pressure to obtain ‘preferential treatment’ or conditions of reciprocity that could undermine real competition.

Employees
We are committed to selecting highly qualified personnel, avoiding any form of discrimination and paying special attention to specific skills and motivational aspects, while not overlooking the potential of the individual. Candidates' professional profiles are assessed solely for the purpose of pursuing business interests.

We do not tolerate or accept any form of irregular work or exploitation, we reject any action that may represent an abuse of authority and that violates the dignity and psycho-physical integrity of the person.

We promote work in a positive, rewarding and non-conflictual work environment and enhance the know-how of our employees, providing them with adequate training and refresher tools.

Our employees receive clear and specific information on the regulatory and economic aspects of their employment.

We guarantee a work environment that complies with current safety and health regulations by monitoring, managing and preventing the risks associated with carrying out our business activities.

Confidential information concerning employees is processed in accordance with current legislation and in a way that ensures maximum transparency for those directly concerned and inaccessibility to third parties, except for justified and exclusive work-related reasons.

Our staff must comply with this Code of Ethics , without reservation and - with diligence and loyalty - with the obligations related to their position. They are required to protect company assets, through responsible behaviour and in line with operating procedures.

Our Collaborators are not allowed to make or accept gifts that may influence or give the impression of influencing the normal course of business negotiations. It is also forbidden to offer money or gifts to executives, officials or employees of suppliers, customers, public administration bodies or other organisations. Gifts of symbolic value may be offered in accordance with applicable laws and customs.

Communication
We recognise the essential value of clear and transparent communication both internally and externally, as a tool for sharing institutional information and as a motivational vehicle for staff.

In external communication, we undertake to disclose only real and truthful information, not to make communications that use harmful texts or images of third parties in general or to disclose untruthful or defamatory competition information.

We are committed to working with the media, without discrimination, respecting each other's roles and the requirements of commercial confidentiality, in order to respond promptly, fully and transparently to their information needs.

Our marketing documentation and communication provides information that corresponds to reality.

In our communication campaigns we are committed to complying with current legislation on privacy and the processing of personal data.

All our relations with public institutions are based on the principles of fairness, transparency and collaboration, while respecting each other's roles. We reject any behaviour that may be even interpreted as detrimental to the above principles.

In business negotiations or commercial relations with the Public Administration, there will be no direct or indirect conduct such as to improperly influence the decision of the counterparty.

In our dealings with trade unions, we are committed to complying with the principles set out in this Code, applicable laws and regulations.

We are committed to complying fully with the regulations in force to protect industrial property and we are committed to always providing original or copyrighted software products accompanied by a license to use them.

Where necessary, we undertake to make specific mention of any third-party software components, incorporated in the products covered by our business.

We operate in such a way as to guarantee the physical and moral integrity of our staff, working conditions that respect individual dignity and safe and healthy working environments, in full compliance with current legislation.

We constantly assess the risks to the safety and health of workers, including the choice of work equipment, as well as the layout of workplaces. The activities of our staff are carried out in technical, organisational and economic conditions that guarantee adequate accident prevention and a healthy and safe working environment.

We are committed to spreading a safety culture to all our staff, developing risk awareness and promoting responsible behaviour, including through appropriate specific instructions. The Recipients of this Code and, in particular, the Employer and its representatives, Managers, Supervisors, Workers, the Safety Officer, and the Company Doctor contribute to the risk prevention and health and safety protection process for themselves, their co-workers and third parties, without prejudice to individual obligations and responsibilities pursuant to the applicable law provisions.

Alcoholic substances or narcotics are banned at the workplace. There is also a ban on smoking at the workplace - in accordance with the law - and in any case in any circumstance in which smoking may cause danger to the company's structures and assets or to the health or safety of colleagues and third parties.

Those who, due to their function, profession or office, have access to privileged information concerning our Company (for example, information concerning management changes, acquisition projects, mergers, demergers, strategic plans, budgets, business plans), may not use it for their own benefit and/or that of family members, acquaintances, and in general of third parties, but exclusively for the performance of their duties and for the purposes of their office. They shall also take special care not to disclose privileged information and to avoid any misuse of such information. Even information and/or any other kind of news, documents or data that are not in the public domain and are related to the acts and activities of each task or responsibility, must not be disclosed, used, or communicated for other purposes without specific authorisation. In any case, confidentiality regarding information concerning the Company and work or professional activity is recommended. We protect all company information and industrial technical experience including commercial information and data; therefore, it is forbidden for recipients to disclose the aforementioned information and experience to third parties unless they are complete or in the exact form or combination of their elements known to the public or easily accessible to experts and operators in the sector.

We accurately and fully record all business activities and operations, in order to implement maximum accounting transparency with legitimate third parties and prevent false, misleading or deceptive items from appearing. Administrative and accounting activities are implemented with the use of up-to-date IT tools and procedures that optimise their efficiency, correctness, completeness and compliance with accounting standards, as well as favouring the necessary checks and controls of the legitimacy, consistency and appropriateness of the decision-making process, authorisation, performance of the Company's actions and operations. We believe that the fairness and transparency of company financial statements are important values.
Every Recipient and any other person required to comply with the rules of this Code must cooperate, for the area of remit, so that the data provided for the invoicing and processing of tax and customs related documentation, are always true and correspond to the operations physically carried out. It is also obligatory for all Recipients, , for the area of remit, to carefully keep all documentation relevant for tax purposes, refraining from concealing, destroying or altering it, while it is forbidden to record transactions in whole or in part that do not exist or that are simulated, as well as use or prepare documentation concerning transactions that do not exist in whole or in part or that are simulated.
For each transaction, adequate supporting documentation must be kept in the records, in order to allow:

• easy entry in the books;
• identification of different levels of responsibility;
• accurate reconstruction of the transaction, also to reduce the likelihood of misinterpretation.

Recipients of this Code of Ethics must avoid all situations and activities in which a conflict of interest may arise between personal economic activities and the tasks they perform within the structure to which they belong. It is forbidden to pursue personal interests to the detriment of the corporate interests, or to make unauthorised personal use of company assets; it is also forbidden to hold shares directly or indirectly of competing companies, customers, suppliers or auditors (except companies listed on free stock markets).

We take appropriate organisational and management measures to prevent unlawful conduct or conduct otherwise contrary to the rules of this Code by any person acting on our behalf. Due to the diversity of our activities, we adopt a proxy system, granting people with appropriate know-how and competence explicit and specific authorities.

The application of the Code of Ethics is entrusted to the CEO who operates - also through specific authorities - in order to:
a) disseminate full knowledge and understanding of this Code of Ethics
b) supervise compliance with the Code and its dissemination to all recipients;
c) verify any news of violations of the Code and inform the competent corporate bodies and functions of the results of the checks, for the adoption of any sanctioning measures;
d) propose amendments to the content of the Code to adapt it to the changing context in which the Company operates and to the needs deriving from the evolution of the Company itself.

Cases of violation of this Code of Ethics may be reported by recipients in a confidential way directly to the Supervisory Body at the following e-mail address odv@ocsnet.it.
The procedures for reporting and verifying violations, also in the interest of the truth, are based on criteria of confidentiality and protection of confidentiality, in order to prevent retaliation of any kind against the person making the report but also in order to ensure verification of the reality of the facts.

The commitment and cooperation of everyone is essential to ensure correct and effective implementation of the Code. Violation of the provisions of this Code of Ethics, taking into account its intensity and possible recurrence, will represent a disciplinary offence and breach of contractual obligations by the employee or functional relationship or professional collaboration, with any ensuing legal and contractual effect and may also represent just cause pursuant to the provisions of the Civil Code, thus giving the Company the right to apply the disciplinary sanctions provided for by the National Collective Bargaining Agreement and the company’s Disciplinary Code

This Code of Ethics has effect immediately from today's date and until revised. All Recipients are obliged to read and observe it.

OCS S.p.A. si impegna a operare in modo etico e responsabile secondo il d.lgs. n. 24 del 10 marzo 2023. Il decreto ha lo scopo disciplinare il processo di trasmissione, ricezione, analisi e gestione delle segnalazioni su informazioni, riferibili al personale OCS S.p.A. relative a violazioni di leggi e regolamenti, del Codice Etico e del Modello Organizzativo 231.

Chi può segnalare

• I vertici aziendali e i componenti degli organi sociali e dell’Organismo di Vigilanza di OCS S.p.A.
• I dipendenti ed ex dipendenti OCS S.p.A.
• I partner, i fornitori, i consulenti, i collaboratori, i soci e, più in generale, chiunque sia in relazione d’interessi con OCS S.p.A.

Che cosa è possibile segnalare
A titolo esemplificativo e non esaustivo:

• violazione del Codice Etico e/o del Codice di Condotta
• violazioni del Modello di Organizzazione e Gestione ex D.lgs. 231/01
• uso improprio di dati riservati dei clienti e dell'Azienda
• illeciti amministrativi, contabili, civili o penali
• atti od omissioni che ledono gli interessi finanziari dell’Unione Europea

Come fare la segnalazione interna
Le segnalazioni possono essere effettuate tramite i seguenti canali:

• In forma orale o scritta tramite la piattaforma Whistleblowing https://whistleblowing.ocsnet.it
• In forma scritta a OCS S.p.a tramite canale cartaceo di posta ordinaria indirizzata all’Organo di Vigilanza (ODV)
  all’indirizzo: Brescia, Via Sorbanella 24, 25125;
• In forma orale, su richiesta del whistleblower, mediante un incontro diretto con uno o più componenti dell’ODV.

Come fare la segnalazione esterna
La segnalazione esterna può essere effettuata nella seguente modalità:

• Canale esterno di segnalazione tramite il sito ufficiale dell’Autorità Nazionale Anti Corruzione (ANAC): https://whistleblowing.anticorruzione.it/#/

Per saperne di più consulta la Procedura Whistleblowing e l’Informativa Privacy.