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CODE OF ETHICS AND CONDUCT

1. INTRODUCTION
2. OUR MISSION
3. OUR VALUES
4. CODE OF ETHICS AND CONDUCT
5. RECIPIENTS
6. CONFLICT OF INTERESTS
7. COMPLIANCE WITH THE LAW AND REGULATION IN FORCE
8. RELATIONSHIPS WITH CLIENTS
9. RELATIONSHIP WITH SUPPLIERS
10. RELATIONSHIP WITH COMPETITORS
11.  RELATIONSHIP WITH COLLABORATORS
12. ACCOUNTING TRANSPARENCY
13. PROTECTION AND CORRECT USE OF THE COMPANY ASSETS
14. CONFIDENTIALITY OF INFORMATION
15. MONITORING COMPLIANCE OF THE CODE OF ETHICS
16. REPORTING OF BREACHES
17. SANCTIONS
18. DISSEMINATION OF THE CODE OF ETHICS AND CONDUCT
19. REFERENCES

1. INTRODUCTION

DCE believes that Ethics in business significantly contributes to success and is a tool to promote corporate image, a key and essential value for our company.

During the years DCE has achieved a leadership position in the credit lifecycle management due to its talent, competence and independence in compliance with the essential principles of fairness, honesty and common sense which are the core of the company’s philosophy, values and business standards.

Any relationship with employees, clients, consultants and collaborators, partners, competitors and colleagues shall be based on such values.

The purpose of this document does not face all working cases. However, it recalls the need of complying with ethical basic principles during everybody daily working activities.

In order to build fair and lasting relationships DCE considers that honesty, sincerity and loyalty are required, shall cover all aspects of the job based on the highest ethical standards.

The rules of this document have the prerequisite to comply with the law and to implement an ethical correct conduct adopted by all company’s representatives and by those who even occasionally operate on behalf of the company.

Among others, Legislative Decree no. 231/2001 considers a particularly strict sanctioning system against those convicted companies and also the introduction of the Code of Ethics.

In conclusion, this Code of Ethics is a reference model for all those who operate in DCE and need to match their behaviors with honesty and loyalty principles.

2. OUR MISSION

DCE

  • We provide competent services;
  • We recognize the key role played by those who operate in our organization;
  • We require consistent compliance with laws, regulations and rules set by our company at all organization levels in order to guarantee company’s reputation and the quality of our service.

3. OUR VALUES

In order to achieve our mission, our work will be always based on the following values:

IMPARTIALITY

We commit ourselves to ensure impartiality or to minimize any threat to impartiality during our activities.

COMPETENCE

We commit ourselves to recruit and motivate our HRs to ensure the highest level of competence and upgrading during their activities.

ACHIEVING EXCELLENCE

We pursue quality in what we do. We look for lasting improvements when we work and we pay a steady attention to details at any level and use efficiently resources.

SOCIAL RESPONSIBILITY AND SAFETY

We commit ourselves to lead our activities as a responsible member of the civil society.

We commit ourselves to operate safely and responsibly to fully comply with Health and Safety at work’s regulation.

4. CODE OF ETHICS AND CONDUCT

This Code of Ethics and conduct is a document approved by DCE including all principles for conduct of business and the commitments undertaken by the Company and its personnel toward both itself and third parties.

The purpose of this Code is to emphasize the company’s commitment to have an ethical behavior in all circumstances, management, employees and all stakeholders, particularly:

  • Comply with laws in force;
  • Operate with fairness and courtesy when working with colleagues;
  • Respect third parties’ interests such as clients, institutions and public authorities;
  • Carry out activities with professionalism and moral integrity.

The principles of this Code are the core of our company policies, best practices and operational procedures implemented.

If clarification is required over some key items connected with both values and culture, some additional guidelines will be issued.

This document states those commitments and ethical responsibilities of the business activities undertaken by DCE and its personnel. The Code of Ethics of the company a key and essential role in the system of internal rules and procedures implemented for transposition of the administrative responsibilities of our company.

This Code sets also how to monitor and verify the compliance with the Code and sanctions for breaches, if any.

5. RECIPIENTS

DCE Code of Ethics is binding for the behaviors of collaborators, both managers and employees. Such commitment is required to consultants, suppliers and third parties having a relationship with DCE. The company will not start or maintain any relationship with those who do not comply with this principle.

Therefore, both company managers and employees are obliged to know its contents, accept and operate in compliance with those principles. Furthermore, the staff are also required to communicate any Code violation to the competent authorities, as described in the last section of this document.

The compliance with this Code rules shall be considered as a contractual obligation of the personnel and third parties having business relationship with DCE.

RULES OF THE CODE OF ETHICS AND CONDUCT (PRINCIPLES AND RULES)

6. CONFLICT OF INTERESTS

In their working routine, every employee, consultant and collaborator is required to avoid any potential conflict of interests, with particular reference to both personal and family interests which may influence the independence of his/her judgement and enter into conflict with DCE responsibilities.

A conflict of interest arises when there is any activity that is, or may be, in contrast with the best company interests. Any real conflict of interest or levied in breach of DCE Code of Ethics shall be immediately reported to Sole Administrator. Employees, consultants and external collaborators cannot work or provide advises, both directly or indirectly, to a competitor or engage themselves in competition with DCE economic interests, including working for a supplier. Clients or contacts’ lists shall not be used to market goods and services, even they are not in competition with DCE services and products. In this company everybody shall avoid any material and financial interest which may be in conflict with DCE needs.

7. COMPLIANCE WITH THE LAW AND REGULATION IN FORCE

DCE strictly operates in compliance with law and regulation in force in those countries where it carries out its business activity, in compliance with the principles of the Code of Ethics of the company and internal procedures. Moral integrity and the compliance with the principles set in this Code of Ethics of the company and internal procedures are required from those who have relationships with DCE and characterize the conduct of the organization.

DCE managers, employees, including all those who operate with DCE, in the context of their respective powers, are required to know and comply with law and regulation in force in all countries where the company operates. In this framework, the attention and the compliance with regulations governing competition at both national and international levels are included.

DCE implements strict accounting principles and internal processes to provide accurate and complete financial information, to maintain adequate internal processes and controls, ensuring that accounting and financial communication are in accordance with the provisions of the applicable law. DCE employees shall perform at their best to support DCE efforts in this field.

8. RELATIONSHIPS WITH CLIENTS

DCE business activity is focused on its Clients’ satisfaction and protection. Therefore any request to encourage quality improvements of both products and services is welcomed. Quality and Social Responsibility policy is consistent with this specific goal and the relationships with Authorities of those who operate on behalf of DCE shall be driven by maximum fairness, transparency and collaboration in compliance with the law, regulation and their institutional functions.

Illegal sums of money and bribes are strictly prohibited by DCE in any circumstance.

It is not allowed to receive or give money, whatever the amount. Personal gifts and preferential treatments both implicit or explicit to obtain business in return for gifts and preferential treatments have never been permitted.

DCE managers and employees are not authorized to take or give illegal sums of money or bribes from and/or to contractors, consultants, suppliers, agents, representatives, competitors or clients. Gifts or promotional materials may be given to Clients if those do not exceed normal courtesy relationships and shall have a modest value in accordance with the law. That should not be interpreted as a favor seeking.

9. RELATIONSHIPS WITH SUPPLIERS

DCE intends to use reliable and loyal suppliers, able to work as a part of a team with internal employees in a relationship based on essential and mutual loyalty, transparency and collaboration. In any event should the supplier, in its business activity on behalf of DCE, adopt behaviors not in line with the general principles of this Code of Ethics, DCE is entitled to take appropriate actions up to foreclosure of any further collaboration. The relationships with the suppliers are governed by common principles and are constantly monitored by DCE administration manager.

The signature of an agreement with the supplier, shall be always based on relations of the utmost clarity, according to the referred procedures.

10. RELATIONSHIPS WITH COMPETITORS

DCE intends to protect the value of fair competition by refraining from activities considered collusive and abusive practice because it believes that collaboration and confrontation are the opportunity to improve its quality standards. Furthermore, DCE always pays attention to verify that other players of the sector do not breach those fair competition rules.

11. RELATIONSHIPS WITH COLLABORATORS

DCE is committed to respect fundamental human rights, laws and regulations in force concerning safety at work in those countries where it operates. Particularly, every employee is hired with a regular work agreement and any form of irregular, illegal and undeclared work is not tolerated.

The assessment of the personnel to be hired, is performed according to the candidates’ profile matching with the requirements and company’s needs, in accordance with the equality of opportunities for those concerned.

Information are required and strictly connected with the assessment of their professional profile and aptitudes respecting both private life and candidate opinions. Personnel are recruited with a regular work agreement with no tolerance of any form of irregular work. At the beginning of work relationship every collaborator receives accurate information about:

  • Functions and tasks to be performed;
  • Regulatory and salary details, as governed by the national collective bargaining agreements;
  • Rules and procedures to be implemented and associated with their working activities.

Such information is submitted to the candidate so that the assignment acceptance is based on an effective understanding. DCE avoids any form of discrimination against its collaborators. In the framework of the processes connected with the management and personnel development, as well as during the recruiting stage, the decisions taken are based on the expected skills matching new hire skills with those who already work in the organization. Their managers fully use and value them by implementing specific tools to foster the growth and the development of the personnel.

Training activities are assigned according specific working needs and professional development inside the company.

DCE is committed to protect environment, health and safety of the workers in compliance with Legislative Decree no. 81/2008 especially with preventive actions. It is also committed to adapt working activities to the person, specifically regarding his/her job design, the choice of equipment and working methods.

Moreover, DCE is working for a lasting improvement of the corporate’s structures and processes efficiency which contribute to the continuity of the services provided. DCE collects and processes personal data, identification data and specific data (former sensitive data) of their employees, natural and/or legal persons with whom it has business relationships. The above process, when required, is implemented with the users’ consent and processed in compliance with terms and limits set by the GDPR EU no. 679/2016 and national current regulation (Legislative Decree no. 101/2018 and subsequent amendments).

Any investigation about ideas, preferences, individual tastes and private life of the collaborators are strictly prohibited. Those standards provide also for the prohibition, without prejudice to the exceptions provided by the law, of communicating and/or disclosing personal data without a prior user’s consent and set the rules for monitoring personal data protection rules by any collaborator.

DCE is committed to safeguard its collaborators’ moral integrity by guaranteeing the right to working conditions that consider the dignity of the person. In this respect, DCE protects the workers from acts of psychological violence and contrasts any discriminatory conduct, behavior and against the person, beliefs and preferences, i.e. perpetrating insults, threats, isolation and excessive intrusiveness, professional restrictions.

Sexual harassment is not tolerated. Behaviors and speeches that may offend people sensitivity shall be strictly avoided, i.e. displaying pictures with clear sexual references, repeated and continuous allusions.

12.  ACCOUNTING TRANSPARENCY

The concept of transparency of the accounting records does not involve only the work of the employees operating in the accounting department, but it applies to both employees and management in any business department where he/she operates. Accounting transparency is based on truthfulness, accuracy and completeness of the basic information for accounting records.

Each employee is required to collaborate in order to correctly and promptly report the operating performances in the company accounting.

Each performance is filed into a specific documentation supporting the activity performed, in order to ensure:

  • Proper bookkeeping;
  • Identification of the different levels of responsibilities;
  • Accurate track of the performance. This also reduces potential interpretation errors.

Each record shall exactly match with what is described in the documents. Each employee has the duty to make documents easily trackable and filed according to logical criteria.

13. PROTECTION AND CORRECT USE OF THE COMPANY ASSETS

Personnel are required to comply with internal rules identifying how to act and related use of IT tools that this company provides to its employees.

Specifically, company’s communication systems, including Internet connections, are used only to carry out business activities and/or business purposes authorized by the management, by relevant company guidelines instructions.

The employee is required to follow assigned password’s instructions and codes any time. Any improper use of the business communication systems means compilation, transmission, recovery, access, display, storage, printing and any dissemination of fraudulent data and materials, including those abusive, threatening, illegal, racial, racial, sexually oriented, obscene, intimidating, defamatory data and materials, and in any case not compliant with a professional attitude.

In addition, company’s intellectual assets including, among others, software program, technical documents and inventions shall be duly handled. The intellectual assets created by the employees when performing their tasks, are transferred and assigned to DCE according to regulations in force,  and/or hiring contract and/or any other agreement, without prejudice to international agreement, local rules or any specific agreement. At the conclusion of the working relationship, personnel shall return all assets belonging to the company, including documents and tools which include DCE information. The former employee is subject to restrictions of both use and dissemination of information owned by DCE.

14. CONFIDENTIALITY OF INFORMATION

Information collected over DCE clients are considered strictly confidential. They are used inside DCE with full compliance with privacy regulation GDPR EU no. 679/2016 and current national regulation (Legislative Decree no. 101/2018 and subsequent amendments) for the purpose of the agreement.

With the exception of those required by the competent Authority, is strictly forbidden to communicate confidential information on debtors of our Clients to third parties.

In order to comply with the principles to protect citizens’ rights as required by the Privacy Authority, DCE has entered the procedures connected with personal data processing inside this Code. (Privacy Authority provision dated 30th November 2005 and GDPR EU no. 679/2016). In fact, invasive or offending practices against human dignity are not admitted and consequently:

  • It is strictly forbidden to unjustifiably communicate information connected with the breach to third parties different from the debtor (i.e. family members, colleagues or neighbors);
  • It is strictly forbidden to use pre-recorded phone communication with the purpose of urging the payment with no operator intervention;
  • It is strictly forbidden to post explicit notices of late payment (reminds that may be read by third parties);
  • It is strictly forbidden to use postcards or envelopes having “credit collection” stamp, including similar information suggesting the receiver’s breach status;
  • It is strictly forbidden to use opened envelopes or externally indicating more data than those required for delivery service;
  • the process shall concern only data needed for the execution of the task, particularly debtor personal data, tax code or VAT number, the amount of debt and delivery data, including phone numbers, usually provided by the concerned party when signing the contract or gathered in lists or public registers:
  • It is strictly forbidden to further use data after the completion of the assignment;
  • It is strictly forbidden to file those concluded together with current dossiers.

If their filing is required pursuant to the law, this shall be made according to specific conditions which prevent standard consultation from data controllers, using specific and logical measures or securing them with data transposition in separate archives, harmonization or pseudonymization.

Confidentiality shall be considered as an essential principle for DCE activities, as a source of trust for its Clients. Therefore, personnel shall strictly comply with that principle, even after the employment relationship has ended.

It is absolutely forbidden to disclose or refrain from improper use of information concerning debtors’ collection as well as those concerning DCE.

15.  MONITORING COMPLIANCE OF THE CODE OF ETHICS

Personnel are accountable for their actions and their own conduct. Furthermore, considering that managers are responsible for others’ actions and are a model for employees, they shall be familiar with the values described in this document and know its implementation. It shall be recalled that none has the authority to request the breach of this code of conduct or influence it. Any attempt to do it, it is subject to disciplinary action.

The compliance with the rules of this Code shall be an essential part of the employees’ contract obligations. It shall be also considered an essential part of the contract obligations of freelancers and/or third parties having business relationship with DCE.

DCE department managers have the responsibility of the employees understanding, meet the company’s expectations and implement the code. Therefore, they shall ensure that the Code commitments shall be implemented at any level of the operational functions.

16.  REPORTING OF BREACHES

With the purpose of ensuring an effective implementation of the Code, DCE requires to all those who discover possible cases of non-compliance of this Code to report that breach.

All employees and collaborators shall report potential breaches or suspicion of infringement directly to Sole Administrator. With reference to any reported breach or attempted infringement of provisions contained in the Code of Ethics, DCE will ensure that no party in the work place will be subject to reprisal, illicit conditioning, hardship and discrimination due to having reported the violation of the contents of the Code of Ethics or internal procedures.

Any retaliation against parties having in good faith reported possible infringements of the Code, is a violation of the Code of Ethics.

Furthermore, those who accuse other employees of the violation, being aware that such violation does not exist, are considered as a Code violation.

17.  SANCTIONS

Any violation of the rules of this Code of Ethics may damage the fiduciary relationship between DCE and those who committed that breach with all legal consequences on company obligation.

The compliance with the rules of this Code of Ethics shall be an essential element of the contract obligations of all those employees pursuant to the Article no. 2104 of Italian Civil Code.

Any breach of the principles established by the Code of Ethics and business procedures, may damage the fiduciary relationship between DCE and those who breaches it, i.e. personnel, clients, suppliers, etc.

Once the breaches are assessed, the implementation of proportioned and specific disciplinary actions pursuant to the law, regardless any criminal implication and criminal proceedings that may arise in case of crime, will be promptly prosecuted.

The disciplinary actions for the violations of this Code, are implemented pursuant to current regulations and related national labor agreements.

18. DISSEMINATION OF THE CODE OF ETHICS AND CONDUCT

This Code has been approved by the corporate bodies, brought to the attention of the employees and third parties which may act on behalf of the company. All those mentioned in this code are required to learn and comply with its contents.

A hardcopy is sent to all employees and current collaborators.

19. REFERENCES

DCE has drawn up this Code in compliance with the Guidelines issued by Confindustria pursuant to the afore-mentioned Legislative Decree no. 231 and subsequent amendments dated 8th June 2001 on the administrative liability of the companies.

Rome, 10th February 2014

Sole Administrator and Legal Representative
Elvio Tagliaferri

 

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