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Governance - Code of Ethics

Code of ethics and disciplinary system

Organization, management and control model

LEGISLATIVE DECREE June 8, 2001, n. 231 (in Gazz. Uff., June 19. n. 140)

General nature

Code of Ethics adopted by Athena Costruzioni S.r.l.s. this is a set of principles and rules, the observance of which is fundamental to the proper functioning of the company.
This Code represents in writing the obligations and fundamental rights by which the company:

  • Explains ethical and social responsibility to various stakeholders, such as shareholders, employees, suppliers and customers

  • Examines the forms of balance and points of balance between the above figures with respect to legitimate expectations.

The adoption of the code of ethics is aimed at promoting a high level of professionalism and prohibiting such behavior, which not only contradicts regulatory acts, but also the values that the company intends to promote through work.
Therefore, according to what is written: individual and collective behavior must be consistent with company policy and must be fully expressed in social responsibility, cooperation and compliance with the current legislation in accordance with the instructions contained in this document.



The Code of Ethics is intended for anyone who establishes a direct or indirect relationship with a company on a stable or temporary basis or otherwise acts for business purposes.
They will be referred to below as "addressees".
All addressees should know the code of ethics and contribute to its implementation and improvement.

General ethical principles and mission of the company

The principles on which the Code of Ethics is based are as follows:

  • Conduct of the company and its various interlocutors ethically and in accordance with applicable law;

  • Loyalty of employees to the company;

  • Correctness, courtesy and respect between colleagues;

  • Professionalism and hard work;

  • Respect for the environment and employee health.

Ethical standards of conduct to which the company intends to adhere:

  • Equity and equity in respect of and recognition of the value of human resources.

  • Hard work, transparency, honesty, confidentiality and impartiality.

  • Protection of human beings and the environment.


Rules and standards of conduct. Guiding criteria in policies towards recipients

  • Impartiality: Provision of job opportunities to all employees, taking into account professional qualifications. Without discrimination on the basis of ethnicity, religion, nationality, sex, age, physical and social conditions;

  • Working environment: Make sure that there are no initiatives in the working relationship that create an
    intimidating, hostile, or isolating working environment.

  • Development: development of skills and competencies of each employee through training and further training;

  • Value of resources: guarantee fair treatment based on merit and competence criteria;

  • Privacy: Protect information related to employees to avoid misuse of this information.

Employees undertake to comply with:

  • Responsibility: to provide services under the contract consistently and responsibly, without delegating to other employees the execution or making decisions related to them;

  • Diligence: observe working hours if there is no good reason;

  • Respect: to behave adequately, respectfully and sensitively towards others;

  • Company climate: Promoting a professional climate in which all colleagues feel positively involved in achieving corporate goals.

  • Integrity: Use the goods and resources provided in accordance with their corporate purpose and to protect their safety and functionality, since each employee is considered directly responsible for the goods and resources entrusted to him to perform duties.

​Employees also undertake to:

  • Do not use the company's landline or mobile phones for personal purposes except in emergency cases.

  • Comply with company rules regarding the use of the Internet and computer system.

  • Confidentiality: information and any materials obtained during the performance of the work are the property of the company. Employees undertake not to disclose information or any other information and documents without special permission.

  • Conflict of interest: avoid all situations and actions in which there may be a conflict between personal economic activity and the duties performed in the company or the interests of the company itself.However, if they occur, maximum transparency and therefore communication with the manager is required. Gifts, acts of commercial courtesy can be received and offered only if they cannot be interpreted in order to obtain personal or corporate benefits improperly.

  • Administrative responsibility: Transparency, accuracy and completeness of the information provided in the financial statements are of particular importance. In this regard, information received in periodic "reports"; or accounting, both general and analytical, must be consistent with the principles of transparency, correctness and completeness. Accounting records should be based on accurate, complete and verifiable information.

Each entry in the ledgers should reflect the nature of the transaction and have appropriate supporting documentation to enable:

  • Convenient bookkeeping;

  • individualization of different levels of responsibility;

  • thorough reconstruction of the process.

Guiding criteria in third-party policy

  • Relations with customers and suppliers: each employee must fulfill his/her duties in order to obtain maximum satisfaction of clients. If necessary, each employee is required to provide assistance and information in a polite, correct and exhaustive manner. Staff members must properly inform third parties of the existence and content of the code of ethics so that each person's conduct meets the criteria of the code of ethics. The selection of suppliers and the determination of procurement conditions should be based on an objective assessment:

    • Quality of required goods and services;

    • Item Price;

    • The ability of the counterparty to deliver and guarantee goods and services promptly at a level appropriate to the needs of the company.


Relations with the state Administration

Employees should not:

  • Promise, offer or accept payments to promote or support the company;

  • Improperly influence the counterparty's decision;

  • Be represented by a third party in the event of a conflict of interest.

In relations with the state administration, it is not allowed:

  • Offer vacancies

  • Request and receive confidential information

  • Offer or provide gifts/services/benefits.


Violation of the Code of Ethics

Violation of the Code of Ethics is detrimental to the trust relations established with the company, therefore, in addition to non-compliance with contractual obligations, it can lead to disciplinary, legal and criminal sanctions, and in the most serious cases - to the termination of labor relations.


Implementation tools

Responsibility for the implementation of the Code of Ethics is currently vested in the Sole Director, who has the right to appoint a "supervisory and supervisory body" consisting of three members, whose term of office is one year.

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