Code of Ethics

This Code of Ethics represents the “Constitutional Charter” of Facile Fisco S.p.A. in which the ethical principles and values ​​that inform the professional culture and which must inspire the conduct and behavior of those who work in the interest of Facile Fisco S.p.A. are collected both within and outside the Federation of lawyers and associated accountants.

The Code of Ethics of Facile Fisco S.p.A. was built through a participatory method, which involved all associates, employees and collaborators, with the aim of defining criteria of conduct with a positive ethical value shared as much as possible within the Federation.

In conclusion, this Document expresses the commitment and responsibility of all associated firms in carrying out the legal and tax profession.

The Code of Ethics of Facile Fisco S.p.A. was born from the will of the founders to express and share, with internal collaborators and in external relations, the professional approach that animates and supports the entire activity of all the studios. The principles and provisions of this Code of Ethics are exemplary indications of the general obligations of diligence, correctness and loyalty that qualify the fulfillment of work performance and behavior in the workplace, as well as the guiding values. All the members and collaborators and associates of Facile Fisco SpA must be inspired in following this work ethic. Through this, Facile Fisco S.p.A. therefore intends to recognize the legal relevance and mandatory effectiveness of the ethical principles and behavioral standards described, to make those who in various capacities have relationships with Facile Fisco S.p.A. responsible. and communicate and promote, also externally, the values ​​of our company.

Furthermore, the Code will be brought to the attention of third parties who receive assignments from the Firm or who have lasting relationships with it, and it is available for consultation to the whole community, Institutions and stakeholders.

FACILE FISCO S.p.A.

(approved by the shareholders unanimously on January 15, 2020

and as per the relative minutes)

Article 1 – Scope of application

The Code of Ethics identifies the guiding values ​​of the Associated Firm and defines the ethical-social profile that must guide the work of each participant to the functioning of the company.

The recipients of the articles contained therein are the shareholders of Facile Fisco S.p.A. associated accountants, employees and any collaborators. Even the companies where the founders of Facile Fisco S.p.A. are present as Shareholders, will have to transpose the contents of this Code of Ethics, preparing internal rules suitable for dissemination and application among the participants in their own functioning.

Article 2 – Liability

The Code of Ethics is also based on non-legal norms, and is aimed at the moral and professional sensitivity of individuals. All participants in the operation of Facile Fisco S.p.A. have the moral responsibility of disseminating and applying the values ​​expressed by the Code of Ethics, with reference to the functions attributed to them. On the occasion of the meeting for the approval of the draft financial statements, the administrator of Facile Fisco S.p.A. will submit to the Shareholders’ Meeting an annual report on compliance with the Code of Ethics within the company, on the activity carried out by him to facilitate sharing and application, and on the results of the controls performed.

Article 3 – Guide values ​​of Facile Fisco S.p.A.

The guiding values ​​of Facile Fisco S.p.A., which must inspire the daily operations of all members of the company, are the following:

• customer satisfaction, understood as the supply of products and services that have the maximum correspondence to the needs, status, culture and expectations of the counterparties;
• personalization of the service, understood as personal involvement in the search for the maximum added value to be attributed to all commercial relations;
• compliance with internal and external regulations, understood as the continuous search for operating methods appropriate to the organization of the company and the provisions of the law, both primary and secondary;
• correctness of conduct, understood as the traceability of conduct to the quality standards described in this Code of Ethics;
• fair remuneration of the risk capital of the company and of the individual participants, understood as the continuous search for an adequate profitability to the complexity and overall riskiness of the activities carried out;
• priority to invest in support of the existing business and constant personal improvement, from a cultural and professional point of view.

The guiding values ​​have equal value and must be perceived by third parties as the factors that distinguish the company’s operations in relation to the competition.

Article 4 – Duty of care

The recipients of the Code act and operate with assiduous and scrupulous care, in compliance with the rules and functions assigned to them, directing their conduct towards the achievement of the company’s objectives and strategy.

Article 5 – Duty of honesty

All the participants in the functioning of the company, operate with justice and moral rectitude and refrain from putting in place situations from which they can derive personal utility, advantage or convenience.

The only income deriving directly or indirectly from the work activity is represented by the salary and remuneration paid by the company.

The recipients of the Code of Ethics are prohibited from:

• accepting gifts or other benefits from subjects in any way interested in the company’s business;
• promise or pay to third parties sums of money, goods in kind, or benefits of any size or value, to promote or favor the interests of the company or other activities and / or subsidiaries or associates.

Small gifts or courtesies of modest value for commercial use are an exception to the above (gifts for advertising or holidays, invitations to conferences, convivial meetings, etc.).

Article 6 – Duty of transparency

In carrying out relations with customers, proper attention must be paid to illustrating the economic aspects, the meaning, the technical structure, the consequences and any risks, in any case providing the customer with information suitable for making decisions.

Written communications, both periodic and occasional, must be clear, complete and easily understandable.

Requests for information and clarifications from customers, both written and oral, must be handled with competence, clarity and timeliness.

In relations with the Revenue Agencies, Social Security Bodies, Guardia di Finanza, Municipalities and with others, the mandatory information must be provided promptly and completely, trying to comply with the requests in the most complete and meaningful way possible.

Article 7 – Duty of confidentiality

The members of the company’s organization are required to maintain strict confidentiality on all facts and documents they become aware of in the performance of their work, with reference to both customers and Facile Fisco S.p.A.

In addition to the areas established by law, professional secrecy includes the internal organization of Facile Fisco S.p.A., internal regulations, projects, ideas and debates, also with reference to facts and situations that are no longer current.

Article 8 – Duty of commercial correctness

In carrying out their daily routine activities, the Associates, employees and collaborators must avoid directing the choices of the customers towards solutions that are not adequate to the culture, the quality standard, the objective needs of the Customers as well as respecting laws.

The activity must always be aimed at satisfying the customer, avoiding engaging in consultancy and services without the reasonable certainty of being able to operate with a quality standard adequate to the expectations and standards of the customers.

Article 9 – Behavior in social life

In all circumstances of social life, and even outside the hours and from the workplace, all members of the organization of Facile Fisco S.p.A. must behave in a way that brings honor to their profession, with a deep awareness of its social utility.

In the context of hours and workplaces, behavior must be inspired by fairness towards colleagues, respect and a spirit of collaboration.

In private relationships, any abuse of the position held that could bring undue advantages for oneself or for others is absolutely forbidden.

Article 10 – Professional training

The quality of human resources constitutes an asset of fundamental importance for the life and development of Facile Fisco SpA, in addition to what is established by law and by employment contracts, the recipients of the Code of Ethics ensure the constant updating of the level of their acquired knowledge, also taking care of the cultural and ethical-deontological training of its collaborators.

Article 11 – Duty of impartiality

Any disputes that may arise within Facile Fisco SpA due to problems of a personal nature and/or inherent in situations between different offices and functions, must be immediately represented with serenity and objectivity to the hierarchically superior officer, which will resolve the dispute taking into account the nature of the problem, in order to carry out operations better, and in the interest of Facile Fisco SpA.

Article 12 – Use of company assets

The use of company assets is strictly functional to the performance of the activities of Facile Fisco S.p.A .. All participants in the organization of Facile Fisco S.p.A. use the company’s assets and equipment with care and diligence, avoiding behaviors that could cause damage, compromise their functioning, or be diseconomic for Facile Fisco S.p.A .

It is absolutely forbidden to use any type of assets of Facile Fisco S.p.A. for their own personal purposes and the removal of documents of any kind and / or use for their own purposes is absolutely prohibited.

Article 13 – Interpretation doubts

The recipients of the Code of Ethics, in any case of doubt on any matter relating to the application of the rules contained therein, given the concrete circumstances, should contact the administrator of Facile Fisco S.p.A. to obtain clarifications on the conduct to take.

Article 14 – Violation of the provisions of the Code of Ethics

Violation of the provisions contained in the Code of Ethics can break the trust relationship between the company and the person responsible for the violation.

In particularly serious cases and depending on the circumstances, the violation of the rules contained in the Code of Ethics may entail the legal and contractual consequences provided for by the rules in force.

Article 15 obligations of shareholders

All the shareholders are expressly committed, in compliance with the deontological rules, to communicate to the administrator of Facile Fisco SpA, periodically, a written list of all the names contacted directly and/or indirectly that may serve the implementation of the Customers, but in in particular, to develop the indispensable knowledge for everyone, and the consequent synergies also between customers and/or the contacted people/companies.

Article 16 – Further resulting from the signing of this Code of Ethics

In order to achieve the objectives deriving from the signing of this Code of Ethics, the undersigned expressly declare to abide by the concept of maximum transparency in their behavior and to act solely and exclusively in favor of the organization they belong to.

Consequently, the undersigned renounce, each for their part, any opposition to verifications against them and should they exist also by law.