Code of Ethics

1. Introduction

ITALIAN MOVING NETWORK Inc. SRL bases its principles on the competence of its collaborators, as well as on the high quality of the service provided to customers and on the attention paid to the needs of the staff, summarising the principles of behaviour that administrators, directors, executives, employees and collaborators in all capacities, and suppliers too, must respect when conducting business activities, carrying out work services and, in general, in all internal and external relations with the Company.

This Code of Ethics, therefore, is to be considered primarily a useful tool for preserving the value and integrity of the company over time, by way of a set of positive principles and rules of conduct, aimed at establishing the principles by which to operate, the standards of conduct and values related to company activities; the purpose being of prevention pursuant to Legislative Decree 231/01 and Anti-corruption Law 190/2013

The Company also aimed to give greater depth to business activities by obtaining the UNI EN ISO 9001: 2015 Quality Certification, which pays particular attention to the organisational and managerial aspects of the Company, with timely references to internal and external resources to the Company, such as Customers and Suppliers.

This code is also consistent with the rules deriving from the GDPR "General Data Protection Regulation" of Legislative Decree 679/2016 and Legislative Decree 81/2008 "Consolidated Law on health and safety in the workplace,

The Code is distributed widely within internal structure,  external communication, as well as throughout its website.

2. General principles

2.1 Legality

The recipients are required to observe all applicable regulations and to update themselves on legislative developments, generally speaking, on regulations in force in the country in which they operate.

The Company considers the transparency of financial statements and accounts to be a fundamental principle for the exercise of its business and for the protection of its reputation.

 2.2 Correctness

Recipients are required to comply with professional rules, and with duties of diligence and of expertise, applicable to transactions carried out on behalf of the Company.

They are also required to comply with Company rules, maintaining correctness and moral integrity, by no means establishing any privileged relationship with third parties for the purpose of obtaining personal advantage, with the commitment to observe the rules and principles of this Code

2.3 Transparency

The recipients are required to respect the clarity, completeness and relevance of the information, and avoid misleading situations in compliance with company regulations, as implementation of the principle of transparency.

2.4 Confidentiality

ITALIAN MOVING NETWORK Inc. SRL undertakes to ensure the protection and confidentiality of personal data in compliance with all applicable regulations with regard to the protection of personal data.

The Recipients are required to by no means use confidential information, acquired during the work activity, for purposes unrelated to the exercise of this activity, and anyhow to act at all times in compliance with the confidentiality obligations assumed by the Company

In particular, they are required to maintain strict confidentiality with regard to documents capable of revealing know-how, transport information, personal and commercial information

3. Relations with employees and external collaborators

3.1 Staff

ITALIAN MOVING NETWORK Inc. SRL promotes the participation of workers in the day to day life of the company, providing participatory tools capable of collecting workers' opinions and suggestions, ensuring their widest participation. pledging to constantly maintain the conditions necessary for professional growth, the knowledge and skills of each person, as well as carry out the appropriate training for professional updating and all initiatives aimed at pursuing this purpose.

The staff in particular must by no means have financial or personal interests in neither the choice of the supplier, nor in competing companies or customers, and may not carry out any work activities that could lead to the onset of a conflict of interest.

The Company steadfastly undertakes to combat mobbing, stalking, all forms of discrimination and in particular any discrimination at all based on race, nationality, sex, age, disability, sexual orientation, political and union opinions, or religious beliefs,  towards any internal or external subject

The relationships between employees must be founded on loyalty, fairness and mutual respect, in observance of the values of civil co-existence and the freedom of people, thus prohibiting any behavior that could be construed as harmful to the employee's dignity and autonomy.

Sexual harassment or acts of physical and/or psychological violence are not to be tolerated. Adler undertakes to protect the moral integrity of collaborators by guaranteeing the right to working conditions that respect the dignity of the individual.

3.2 Consultants and external collaborators

Relations with external consultants and other collaborators are based on a selection of counterparties of adequate professional qualification and reputation; it is mandatory to establish transparent and collaborative relationships, ensuring both the association between quality of service and cost and the application of contractual conditions, by requiring compliance.

Relations with agents are governed by formalised contractual relationships in which the conditions, the subject of the contract and the methods of collection and remuneration must be specifically indicated.

It is not allowed to offer services or make payments to collaborators who do not represent a justified position in the context of the contractual relationship

The violation of the principles of legality, correctness, transparency, confidentiality and respect for the dignity of the individual are just cause for contractual termination

4. Relationships with customers and suppliers

4.1 Customers

The staff is required to deal with third parties in a courteous, competent and professional manner, since this behavior is crucial for the protection of the company's image and reputation and consequently for the achievement of corporate objectives.

In particular, one must refrain from any form of unfair or deceptive behaviour that could induce customers or suppliers to trust in unfounded facts or circumstances.

Contacts and communications with customers must be clear and simple, in accordance with company and commercial policies and also entire, so that no element relevant to the customers’ decisions may be neglected.

The staff is required to strive for punctual and high quality service, and to limit any form of disservice or delay, as a means of optimising customer satisfaction.

4.2 Suppliers

The relationship with, and choice of, suppliers is based on loyalty, correctness, transparency, efficiency and economy. It is not permitted to choose suppliers based on subjective and personal decisions or, at any rate, by virtue of interests that may conflict with those of companies.

The Company must carry out every possible control so that suppliers and customers too are able to respect the fundamental ethical principles set out in this Code.

5. Business management

5.1 Use of company assets and IT systems

All documents, work tools, equipment and any other goods owned by ITALIAN MOVING NETWORK Inc. SRL, are to be used exclusively for the realisation of business purposes; use for purposes not strictly related to professional activity is not permitted, and all abovementioned goods must be used and kept with the same care as that devoted to personal possessions.. All company information and know-how are subject to a duty of confidentiality and must continue to be observed even after the termination of the relationship with the company. IT and telecommunications tools (such as telephones and faxes, e-mail, internet) are available to staff as work tools and, consequently, must be used exclusively for corporate purposes: this applies to the use of both personal computers and to other tools, programmes and services.

In particular, personnel are prohibited from:

- uploading personal or borrowed unauthorised software to company systems, as well as from making unauthorised copies of licensed programmes for personal, corporate or third party use.

- allowing unauthorized persons to use the goods and equipment made available to them by the Company;

5.2 Accounting management

In accounting management, the company is called to act in compliance with the principles of truthfulness, accuracy and transparency. Each operation must be recorded and accompanied by appropriate supporting documentation, in order to allow straightforward accounting recognition and accurate reconstruction of the operation. Each survey must match exactly what is shown on supporting documentation. Employees are required to collaborate so that the documentation may be easily found and ordered according to logical criteria. Any person within the Company who becomes aware of episodes of omission or falsification of accounting data or of the documentation on which the accounting records are based, must inform their superiors or the Administrator of whatever has been found during the exercise of their functions.

6. Confidentiality of information and data

Employees and/or collaborators must regard confidentiality as a vital principle for the conduct of business, and as a fundamental principle for the reputation of the company and for the trust that customers place in it. The information is managed in accordance with the provisions of the applicable GDPR 2016/679 legislation

7. Occupational Health and Safety

ITALIAN MOVING NETWORK Inc. SRL promotes and guarantees the health and safety in the workplace of its employees as well as of all those who access their offices and work environments.

The Company undertakes to guarantee working conditions that respect individual dignity and a safe and healthy work environment, also by way of the diffusion of a culture of safety and risk awareness, promoting responsible behavior by all in compliance with company procedures and current accident prevention regulations.

Each and every employee is required to contribute personally to maintaining the safety of the working environment in which he operates,  to behave responsibly for his own and others' protection and to take care of his own health and safety and that of other people present in the workplace, in accordance with the training,  instructions and means provided by the employer.

Environmental protection is taken into the utmost consideration, furthermore pursuing the improvement of the environmental conditions of the community in which it operates, in full compliance with current legislation. In particular, the Company promotes actions aimed at the differentiation in collection, recycling and correct disposal of waste, paying particular attention to the selection of service providers dedicated to waste management.

Drug use, alcohol abuse, or the taking of illegal substances will not be tolerated in the workplace.

8. Compliance with the Code of Ethics

The violation of the rules of this Code of Ethics is harmful to the relationship of trust established with the Company and may lead to disciplinary actions and damages.

The observance of this Code by employees and collaborators and their commitment to respect the general duties of loyalty, correctness and execution of the contract of employment in good faith must be considered an essential part of the contractual obligations.

The behavior of employees, in violation of the behavioral or procedural rules contained in this code of ethics, must be considered to be disciplinary offences punishable in compliance with applicable legislation.

The observance of the code of ethics by third parties (suppliers, consultants, etc) is integral to the obligation to fulfill the duties of diligence and good faith in negotiations and in the execution of existing contracts with the company

Sanction system

Violations of this Code, with the exception of any different or further liability profile, constitute a contractual violation against the Company

Anyone who violates the provisions of this  Code, may be assessed for the purposes of disciplinary proceedings and for the imposition of penalties provided for in the current National Collective Labor Agreement ("CCNL"),  in compliance with the principle of progressive sanction and proportionality to the seriousness of the infringement.