Code ethics

Index

Introduction
1. Introduction and methods of implementation and control
2. Ethical principles of reference
3. Rules and standards of conduct
4. Improvement goals

Introduction

Definition

The Code of Ethics is the set of rights, duties and responsibilities of the Company towards all its stakeholders; it contains principles and rules of conduct, through which behaviors are implemented, which enrich corporate decision-making processes and guide the actions of the Organization. The Code of Ethics expresses the “ideal social contract” of the Company and translates into principles and operating rules the ethical criteria adopted in balancing the expectations and interests of the stakeholders.
For this reason, the Code of Ethics is a mean for governing relations between the Company and its stakeholders and for strategic management, as well as that of employees’ behaviours. Furthermore, it is an instrument for making sensible and reasonable judgments on reliability and good reputation of the Organization.
The Code of Ethics is a document officially approved by the governance body, which commits top management and all collaborators of the Organization. Finally, it is a voluntarily adopted instrument to be read contextually to all the various official procedures that regulate the business context.

Recipients

This Code applies to all employees of the Company regardless of their role and seniority and to all other professional who act on behalf of the Company. Arca24 makes every effort to ensure that all the interested parties are aware of the contents of this Code, which is made available to all collaborators.

Function of the instrument

Moral legitimacy function. The rights and responsibilities of the Company towards the stakeholders expressed in the Code of Ethics offer the terms under which all stakeholders can recognize whether their expectations and expectations are treated equally. The standard of balancing expectations becomes the basis for agreement and cooperation mutually beneficial.
Cognitive function. The Code of Ethics makes it possible to recognize unethical (opportunistic) behaviors and to clarify the exercise appropriate (not abusive) of the authority, discretion, delegation and decision-making autonomy of each participant to the Company and to each stakeholder.
Incentive function. The Code of Ethics generates incentives to observe the principles and rules contained therein, from the moment that the construction of the organization’s reputation and the establishment of relationships of trust depend on their observance mutually beneficial between the Company and its stakeholders.

Content

The Code of Ethics is divided into the following parts:

Introduction and methods of implementation and control
First of all, it provides a definition of the Code of Ethics, the mission and the general ethical vision of the Company. It contains also a description of the main mechanisms and bodies set up by the Company in order to implement, monitor and disseminate the respect and compliance with the Code of Ethics.
Furthermore, the document presents management policies, aimed at providing general indications for responsible management of the company.
Ethical principles of reference
- They establish the responsibilities, that is, the fiduciary duties of the Company towards its stakeholders.
- They identify the expectations of the various stakeholders that are believed to have a moral legitimacy towards the Company and their level of fair satisfaction. Finally, they establish the fair treatment of the aforementioned expectations of each stakeholder.
A particular idea of a fair balance between the legitimate interests of the various stakeholders emerges from the set of principles.

Principles they are abstract and general and apply to multiple events, including those that you are initially unable to predict.

The principles require conformity and reciprocity. The compliance request is essential because reputation depends on it. Only with the observance of the ethical principles that the Company has chosen, can it increase its own reputation and trust of stakeholders.

All those who contribute to the realization of the mission are requested to comply with the rules of the Code of Ethics.
Rules and standards of conduct
Rules of conduct and standards of conduct should only be formulated after having carefully identified and analyzed the “critical areas” in relations with stakeholders, that is the issues and situations in which cases of opportunism or unethical behavior.
It is necessary to identify the abstract cases of opportunism or unethical behavior “typical” of the company activity.
Standards can be of two types:
- prohibitions: in risk areas a negative rule (prohibition) consists in the recommendation to avoid the materialization of a particular cases of opportunistic behavior. These rules govern the areas at risk in relations with each stakeholder (purchasing, personnel selection, gifts and benefits, selection and advancement, quality control, execution of contracts, environmental impact, etc.)
- preventive standards of behavior : rules and procedures of a precautionary nature that prescribe positive behavior by conforming to which the company or its collaborators are able to prevent the formation of a case of opportunism, so that when ethical risk situations arise it is possible to ascertain that, given compliance with the procedure, the conduct does not deviates from observance of the relevant principles.
Improvement goals
The improvement objectives concern the most relevant issues for the business and the socio-environmental impact of the company’s activities, for which Arca24 believes that continuous monitoring and improvement are necessary.

1. Introduction and methods of implementation

This Code of Ethics expresses the commitments and ethical responsibilities in the conduct of business and company activities undertaken by collaborators of Arca24, in compliance with the legitimate interests of the property, employees, customers, business partners and the communities in which

Arca24 is present with its own activities.

All collaborators undertake to research, practice and induce to adopt the rules contained therein in order to contribute concretely, in
first of all through its own behaviors, to the improvement of company performance and the socio-economic system e
environmental.
The ethics of conduct cannot be assessed only in terms of strict compliance with the law and this Code of Ethics. It is based on the convinced adherence to the highest standards of behavior in various situations.

ARCA24 MISSION
Arca24’s mission is to create a positive economic, social and environmental impact through innovative solutions aimed at making the recruiting and human capital management process more efficient, in compliance with the regulations in the field of Security and Data Processing.

THE VISION OF ARCA 24
Arca24’s Vision is to be a leader in developing HR software solutions with the help of innovation and offering the best digital HR experience through the use of technologies that enhance human skills.

In our corporate culture prepared for the identification of problems and the contextual proposal for a solution, the main values of Arca24 are the following:

Communication and Responsibility
Listening and Curiosity
Passion and Collaboration
Innovation and Impact
Humility and Service
Transparency and Integrity

ETHICAL VISION AND STAKEHOLDER INVOLVEMENT
Arca24 respects the legitimate expectations of its stakeholders, i.e. those subjects (intended in the sense of individuals, groups, organizations) who have significant relationships with it and whose interests are involved in various capacities in the activity of Arca24.

In particular, stakeholders are those who make investments related to the activities of Arca24 and, therefore, collaborators, customers, suppliers and business partners. In a broader sense, all those individuals or groups as well as organizations and institutions are also stakeholders, which interests are influenced by the direct and indirect effects of Arca24’s activities for the exchange relationships that entertain with it or because they are significantly influenced by it: local and national communities, environmental associations, etc.

In the conduct of business, unethical behavior compromises the relationship of trust between Arca24 and its stakeholders and generates hostile attitudes towards the Organization.

Arca24 aspires to maintain and develop the relationship of trust with its stakeholders and seeks to continue its mission by seeking reconciliation of the interests involved. This Code of Ethics is therefore based on an ideal of cooperation in view of a reciprocal benefit of the parties involved.

Specifically, Arca24 is careful to guarantee a structured and continuous dialogue with its stakeholders through various tools, which can operate continuously (for example, internal communication with employees) or consist of ad hoc initiatives.

Below is a table of the main communication channels used by Arca24 in dialogue and involvement according to the policy of stakeholder engagement.

STAKEHOLDER

MAIN ENGAGEMENT ACTIVITIES

CLIENTS

Customer satisfaction and market analysis
Support to activities carried out by customers
Customer care
Pre and post-sales assistance
Direct contacts at sector events and trade fairs
Direct emailing to selected lists to disseminate initiatives and / or collect feedback and input

SUPPLIERS AND PARTNERS

Evaluation activities envisaged by the certified systems
Technical audits and periodic meetings
Collaborations for improvement or innovation

COLLABORATORS

Internal communication events
Meetings to share objectives and update the Code of Ethics
Working groups on strategic projects
Reserved channel and e-mail box for reports
Constant monitoring of the climate and occasional surveys to understand the needs of work-life balance o
other
Team building

SHAREHOLDERS AND FINANCERS

Participation in events and international conferences
Involvement in formulating and revising the Code of Ethics
Periodic publication of company financial results

ENVIRONMENT AND FUTURE GENERATIONS

Participation in conferences and refresher courses
Participation in innovative projects with scientific institutions and their correct communication
Collaboration in controls by the bodies in charge
Partnership with suppliers and specialized organizations

LOCAL COMMUNITIES

Projects with cultural and artistic institutions
Participation in conferences and co-Company of events
Invitations and meetings with local institutions

PUBLIC INSTITUTIONS

Collaboration in the visits or checks of the Public Administration
Participation in thematic institutional tables
Participation in projects, calls or institutional research

SCOPE OF APPLICATION OF THE CODE
The established rules of conduct apply to all actions, transactions and trades carried out and, in general, to all conduct put in place by Arca24 collaborators or employees.

The Code of Ethics is valid both in Switzerland and abroad, also in consideration of the cultural, social and economic diversity of the various countries in which Arca24 operates.

Recipients of the Code of Ethics are all the people who work with and for Arca24: the property and collaborators, without any exception, and all those who, directly or indirectly, permanently or temporarily, establish relations or relations with the Company and work to pursue its objectives.

The owners and collaborators of Arca24 have the obligation to know the rules, refrain from conduct contrary to the rules, contact to the superior or the person in charge for clarifications or complaints, collaborate with the structures responsible for verifying violations and inform counterparties of the existence of a Code of Ethics.

In particular, the management is required to observe the Code of Ethics in proposing and implementing the projects, actions and investments of the Company and the members of the governance body must be inspired by the principles of the Code of Ethics in setting the objectives.

Those who occupy positions of responsibility in Arca24 are in fact required to be an example for their employees, to guide them in compliance with the Code of Ethics and carefully selecting employees and collaborators who guarantee maximum commitment in compliance with the rules.

They must also report to the authority in charge all useful information about any deficiencies in controls, suspicious behavior, etc., to prevent retaliation and to modify the control systems of one’s function upon the recommendation of the authority.

Arca24, through its collaborators, undertakes to avoid retaliation, to collaborate with the judicial authorities, to foster a culture company characterized by the awareness of existing controls and a mentality oriented to the exercise of control. It will also try to update the Code of Ethics in order to adapt it to the evolution of civil sensitivity and the regulations of relevance for the Code of Ethics itself.

In every project and business relationship, all counter parties must be informed of the existence of rules of conduct and must respect them, under penalty of the consequences established by the contract.

ESTABLISHMENT OF THE AUTHORITY FOR MONITORING THE CODE OF ETHICS
In order to ensure compliance with the rules and principles expressed, a specific internal authority is identified to carry out activities of supervision and monitoring of the application of the Code of Ethics which are responsible for the following tasks:

constantly monitor the application of the Code of Ethics by the interested parties, also through the acceptance of any reports;
report any significant violations of the Code of Ethics;
express binding opinions on any revision or update of the Code of Ethics or the most relevant policies e
company procedures, in order to ensure consistency with the Code of Ethics.

This Supervisory Body is currently constituted by the CEO, the Legal Manager and the HR Manager. The Control Body of the Code of Ethics has its own dedicated e-mail address to which you can write for reports / suggestions: organismocodiceetico@arca24.com.

COMMUNICATION AND TRAINING
Arca24 undertakes to submit the Code of Ethics to the interested parties (including new collaborators) through specific communication and training. This Code and the provisions relating to it are available to all workers on the on line notice board.

In order to ensure the correct understanding of the Code of Ethics, periodic plans are prepared and implemented by the Management.

The planning of information / training meetings must be carried out at least annually.

Verification of the effectiveness of the training / information activity conducted is carried out during the periodic evaluation of the employees.

It should also be noted that Arca24 periodically conducts internal audits aimed at verifying compliance with all rules, standards and practices companies, with particular attention to socio-environmental issues.

REPORTING VIOLATIONS OF THE CODE OF ETHICS
All interested parties can report, in writing via email and in non-anonymous form, any violation or suspected violation of the Code of Ethics to the Supervisory Body for the implementation of the Code itself, which:

analyzes the report, possibly listening to the person responsible for the alleged violation;
acts in such a way as to guarantee the whistleblowers against any type of retaliation, understood as an act that may give rise to even the only suspicion to be a
form of discrimination or penalization;
ensures the confidentiality of the reporting person’s identity, without prejudice to legal obligations.

In the event of ascertained violation of the Code of Ethics, the Supervisory Body will inform the governing body of the Company.

The competent corporate functions, activated by the aforementioned bodies, will define the measures to be adopted in accordance with the regulations in force and according to the disciplinary system adopted by the Company.

PENALTY SYSTEM
Compliance with the rules of the Code of Ethics must be considered an essential part of the contractual obligations of employees. The violation of the rules of the Code of Ethics may constitute a breach of the primary obligations of the employment relationship or a disciplinary offense, with any consequence of the law, also with regard to the preservation of the employment relationship, and may entail compensation for damages.

Compliance with the Code of Ethics must also be considered an essential part of the contractual obligations assumed by collaborators and / or by subjects having business relations with the Company. Violation of the rules of the Code of Ethics may constitute a breach of the contractual obligations, with all legal consequences, also in relation to the termination of the contract and / or the assignment and may entail compensation for damages deriving from the same.

APPROVAL AND UPDATING OF THE CODE OF ETHICS
Arca24 approves this Code of Ethics which is subject to periodic review in the event the national and international regulations will change. Such regulations are considered as best practice.

2. Ethical principles of reference

2.1. Responsibility

Responsibility represents the fundamental principle for all the activities of Arca24, its initiatives, its projects and its communications and constitutes an essential element of business management.

Responsibility leads to feeling – and making others feel – responsible for one’s actions, the consequences thereof and to maintain commitments. Relations with stakeholders, at all levels, must be based on criteria and behaviors of fairness, collaboration, loyalty and mutual respect.

2.2.Compliance with laws and regulations in force in all countries where Arca24 operates
Arca24 undertakes to comply with all national and international laws and directives and all generally recognized practices.
In the event that these are proven to be incomplete or in contrast with the principles of our legal system or subject to different interpretations, the most qualified experts will be consulted.

2.3.Transparency and completeness of information
Arca24 undertakes to inform all stakeholders in a clear and transparent manner at least once a year about its situation and its performance, without favoring any interest group or single individual.

2.4. Confidentiality of information
Arca24 ensures the confidentiality of the information in its possession, compliance with the regulation on personal and sensitive data and refrains from seeking confidential data through illegal means.
Arca24 collaborators are expressly required not to use confidential information for purposes not connected with the exercise of the own business.

2.5. Fight against corruption and conflicts of interest
Arca24, in coherence with the values of honesty (indicates the human quality of acting and communicating in a sincere, loyal manner and on the basis of moral principles considered universally valid, avoiding carrying out reprehensible actions towards others) and transparency (metaphorical extension of the meaning of the word “transparent”: it implies openness, communication and responsibility) undertakes to implement all measures necessary to prevent and avoid corruption or conflict of interest.
In particular, it does not allow sums of money to be paid or other forms of corruption exercised in order to procure advantages direct or indirect to Arca24 itself. Prohibits the acceptance of gifts or favors from third parties that go beyond the normal rules of hospitality and courtesy.
Arca24 will ensure that its employees and / or collaborators are not involved in relationships that could lead to conflicts of interest with their corporate role.

2.6. Innovation and change
Innovation involves challenging the “status quo” by always seeking opportunities to improve: changing the current state to achieve a new state through change and transformation.
Arca24 is committed to create value through concrete changes aimed at resolving disharmony and human well-being and the environment.
Innovation without value creation is not sustainable in the long term.

2.7. Protection of intellectual assets
Arca24 ensures the protection of the organization’s intellectual assets, allowing access only to authorized persons and avoiding the use of confidential information or tools by employees for purposes other than the exercise of their business. Arca24 also guarantees the conservation and protection of the creative, technological and physical assets.

2.8. Centrality of the person
Arca24 promotes the centrality of the person, respect for his physical and cultural integrity and respect for the dimension of relationship with the others.
In particular, Arca24 protects and promotes the value of human resources, in order to improve and increase the assets and competitiveness.

2.9. Human rights
Arca24 supports and respects human rights in accordance with the UN Universal Declaration of Human Rights.
Arca24 recognizes the fundamental rights of workers as defined by the International Labor Company: freedom of trade union association, right to collective bargaining, abolition of forced labor, elimination of discrimination in the field of work and employment. Arca24 recognizes the freedom of trade union association to its employees and has given itself, with effect from 1 November 2020,
its own internal employment contract drawn up in concert with a trade union body, and aimed at the greater protection of workers.
Arca24 does not make use of child labor and has no relationships with suppliers or collaborators who allows it. Arca24 does not allow any behavior that represents physical coercion, threat, offense or abuse (gestures, language, physical contact or similar behaviors).
Therefore, requests and threats aimed at inducing people to act against the law and the Code of Ethics, and to adopt behaviors detrimental to the beliefs and moral preferences of each person are avoid.

2.10. Impartiality and equal opportunities
Arca24 avoids any discrimination based on age, gender, sexual orientation, state of health, nationality, opinions, policies and religious beliefs, in all decisions that affect relationships with its stakeholders, such as the choice of customers to serve, personnel selection and management, work organization, supplier selection and management, relationships with the surrounding community and the institutions that represent it.
In particular, Arca24 selects its employees and determines their duties based on their personal qualities and skills professionals with the intention of maintaining a lasting and mutually profitable professional relationship.

2.11. Health & Safety
Arca24 undertakes to ensure its employees safe, healthy and, to the extent possible, pleasant working conditions, guarantees the physical and moral integrity of its collaborators, working conditions that respect individual dignity and work environments safe and healthy. For this, it works to prevent accidents at work and damage to health through programs and actions aimed at minimizing, as far as possible, the risks deriving from the work environment.

2.12. Diligence and fairness in managing contracts
Contracts and work assignments must be carried out as mutually established by the parties.
In existing relationships, anyone who works in the name and on behalf of Arca24 should not try to take advantage of contractual gaps, or unforeseen events, to renegotiate the contract for the sole purpose of exploiting the position of dependence and weakness in which the interlocutor has come to visit.

2.13. Quality of services produced
Arca24 directs its business to the maximum satisfaction and protection of its customers by listening to the requests they can encourage an improvement in the quality of products and services.
For this reason, Arca24 directs its research, development and marketing activities towards high standards of quality and usability of its services and products, identifying opportunities, challenges and resource needs in a global context, not just within local borders.

2.14. Loyalty and fair competition
Arca24 intends to protect the value of fair competition by refraining from collusive, predatory behavior and abuse of dominant position. Arca24 undertakes to avoid any form of unfair competition towards other professionals or colleagues and to refrain fromdisparaging appreciations towards them.
In particular, fair competition is the foundation for the correct relationship between the shareholders and collaborators of Arca24, who undertakes to maintain the confidentiality of Arca24 innovations and respect their choices. The loyalty between Arca24 partners and collaborators also continues in the event of any abandonment or removal from the Company.

2.15. Environmental sustainability
Arca24 contributes constructively to ecological sustainability in all its activities and for the properties entrusted to it, in consideration of the rights of future generations.
Arca24 collaborates with its customers and partners to develop advanced processes and methodologies for the efficient and sustainable use of resources, for the compensation of emissions, for the prevention of pollution and for the recovery of polluted areas.
Arca24 respects the expectations of its customers and society regarding environmental issues. In particular, Arca24 is committed for a plastic free office providing all employees with glass bottles and taking care of the purification of running water. Moreover, Arca24 is attentive to the separate collection of waste.

2.16. Responsibility towards the community
Arca24 is aware of the effects of its activity on the reference context, on economic and social development and on well-being general community and pays attention to the importance of social acceptance of the communities in which it operates.
For this reason, Arca24 evaluates the conduct of research and investments in respect of local and national communities, and support initiatives of cultural and social value in order to obtain an improvement of its reputation and legitimacy to operate.

3. Rules and standards of conduct

3.1. General guidelines

Those who act in the name and on behalf of Arca24, must maintain an ethical and law-abiding behavior, pursuing maximum transparency, clarity, correctness and efficiency in business relations of interest to the same, and in relations with third parties and the authorities.

The achievement of corporate objectives must be pursued through systems that guarantee maximum effectiveness and efficiency operational. The company objectives, however, must be possible, specific, concrete, measurable and related to the time schedule for their achievement. It must always be possible to verify and control every decision-making process, authorization, registration and carrying out operations, activities and services, through adequate instrumental support; all information and accounting records they must be truthful and complete.

The use of illicit means is prohibited under any circumstances.

Operations and transactions must be adequately supported at a documentary level in order to be able to carry out checks certify roles and responsibilities, characteristics and motivation of the operations themselves.

Arca24 declares not to continue any relationship with anyone who proves not to share the aforementioned principles and the rules of conduct prescribed by the Code of Ethics.

3.2. Partners and collaborators

DILIGENCE
The relationship between Arca24 and its employees is based on mutual trust: employees are therefore required to work to encourage the interests of the company, in compliance with the values set out in this Code of Ethics. Employees must refrain from any activity they may configure a conflict with the interests of Ark24 giving up the pursuit of personal interests.

The employee is required to observe the instructions given by his / her superior or by his / her hierarchically superior collaborators for the carrying out the work.

Each worker is materially responsible for the tasks entrusted to him and is personally liable for damages or damages losses caused to Arca24, within the limits attributable to it in accordance with the law.

LOYALTY
The obligation of loyalty IS aimed at protecting the employer’s interest and the company’s ability to compete.

Employees are required not to use and / or disclose confidential information, learned as a result of their work, for purposes unrelated to the exercise of this activity, and in any case to always act in compliance with the confidentiality obligations assumed by Arca24 towards of all stakeholders. In particular, employees are required to maintain the utmost confidentiality on documents suitable for disclosing know-how, commercial information, corporate transactions, personal information concerning software users. The employee cannot perform competitive activity with respect to the typical activity of the company. Arca24 undertakes to ensure the protection and confidentiality of personal data of employees and even more absolutely that of its Customers / Users, in compliance with all applicable legislation on the subject of protection of personal data.

COMMUNICATION AND PROACTIVITY
Communication between collaborators is necessary to ensure the success of each person’s performance in exercising their own tasks. Arca24 provides all collaborators with the tools for clear and timely communication (in addition to e-mails, Arca24 has made available efficient communication tools such as Teams) as well as direct communication in the office or by telephone.

In case of doubts, it is always recommended to proactively contact the collaborator who will be able to clarify the doubt promptly, thus obtaining an ideal solution of the case in a short time.

EMPLOYEES’ SELECTION
The evaluation of the shareholders and people who work with Arca24 is carried out on the basis of the correspondence of the candidates’ profiles with respect to those expected and organizational needs, in compliance with the principles of impartiality and equal opportunities for all interested parties.

The information obtained in this context is strictly connected to the verification of the aspects required by the professional profile required, respecting the candidate’s privacy and opinions.

All appropriate measures are taken to avoid favoritism, nepotism, or forms of clientelism in the selection phases of the personal.

Each employee must have a regular employment contract; no form of irregular work is allowed. When the collaboration begins, the collaborator must receive exhaustive information regarding the characteristics of the duties and the function, the regulatory and remuneration elements and the regulations and conduct for the management of health risks personal.

INTEGRITY AND PROTECTION OF THE PERSON
Arca24 undertakes to protect the moral integrity of its members and collaborators, guaranteeing the right to working conditions that respect the dignity of the person. For this reason, it safeguards collaborators from acts of psychological violence and counteracts any attitude or discriminatory or harmful behavior of the person, his beliefs or preferences.

Any behavior harmful to people’s sensitivity is not allowed.

Employees who believe they have been harmed or discriminated against for reasons related to sexuality, health, nationality, political opinions, religious beliefs, etc. or any other reason not justified on the basis of objective and reasonable criteria, can report the incident to Arca24, which will be required to carefully evaluate the actual violation of this Code of Ethics.

DUTIES OF MEMBERS AND COLLABORATORS
Each member and collaborator of Arca24 must act loyally in order to favor the interests and growth of Arca24 and the fulfillment of its Mission, respecting the obligations underwritten by one’s employment contract and by the provisions of this Code of Ethics, ensuring the services required of him.

Conflict of interest
Each employee is required to avoid any situation in which a conflict of interest may arise and must refrain from drawing personal advantage from business opportunities of which he became aware in the course of carrying out his duties.
By way of non-exhaustive example, the following situations may cause a conflict of interest:

perform top management functions and have economic interests with suppliers, customers, or competitors (possession shares, professional appointments, etc.) also through their family members;
managing relations with suppliers and working for a supplier, including through family members;
accepting money or favors from people or companies that have or intend to enter into business relationships with Arca24.

Shareholders are required not to have economic interests with competitors (possession of shares, professional appointments, etc.) also through the family members.

In the event that even the appearance of a conflict of interest arises, the shareholder or collaborator is required to inform their managers (who will take care of instructing the company structure specifically identified to manage the situation).

With regard to Human Resources, for anything not expressly indicated in this section, please refer to the Collective Labor Agreement and the internal procedures of Arca24.

3.3. Clients

BEHAVIOR WITH CUSTOMERS
Arca24’s behavior towards customers is based on availability, respect and courtesy, with a view to collaborative and highly professional relationship.

Consistently with the principles of impartiality and equal opportunity, Arca24 undertakes not to arbitrarily discriminate against its customers.

RESPONSIBLE MARKETING
Marketing activities enhance corporate strategies based on ethical behaviors and practices that aim to obtain benefits and advantages for the company itself and represent a fundamental element for sustainable development. Responsible marketing policies are based on activities of constant coordination of the communication channels, in order to promote the diffusion of the “Arca24” brand, by ensuring a good perception of the Company in the reference market, protecting the business and improving the quality of the services rendered, in constant compliance with this Code of Ethics.

Through ethical marketing it is possible to create the corporate reputation and a value for the company, increasing the experience of users, monitor the redemption of activities and the degree of customer satisfaction.

COMMUNICATIONS AND CONTACTS TO CUSTOMERS
Communications and contacts with Arca24 customers and potential customers (including advertising messages) must be:

clear and simple, formulated in a language as close as possible to that normally used by the interlocutors;
compliant with current regulations (where applicable) without resorting to elusive and in any case incorrect practices;
complete, so as not to overlook any element relevant to the understanding by the customer;

The purposes and recipients of the communications determine, from time to time, the choice of the contact channel (chat, telephone, e-mail, social media,etc.) more suitable for the transmission of contents without using excessive pressure and solicitations and committing not to use misleading or untrue advertising tools and in any case in full compliance with the applicable regulations regarding the processing of personal data.

QUALITY AND CUSTOMER SATISFACTION CONTROL
Arca24 obtained ISO 9001: 2015 certification at the end of 2019 and is committed to maintaining standards on a daily basis qualitative. Furthermore, it intends to implement suitable strategies for obtaining ISO 27001 certification.

Arca24 undertakes to guarantee adequate quality standards of the services / products offered on the basis of predefined levels and to monitor periodically the perceived quality.

Arca24 undertakes to always respond to suggestions and complaints from customers and associations for their protection, making use of suitable and timely communication systems (for example, customer service services, e-mail addresses, etc.) for all customers.

The company has foreseen the creation of a structured plan for monitoring customer satisfaction, which will also allow the evaluation of the indirect results obtained by its customers through the use of its products or services. The results of these investigations will come periodically shared with the staff and will guide strategic corporate decisions.

GIFTS AND OTHER FORMS OF BENEFITS
No form of free gift or benefit, promised, offered or received, which could be interpreted as exceeding normal commercial or courtesy practices, is allowed.

This rule does not allow exceptions even in those countries where offering gifts of value a business partners is considered customary.

In any case, Arca24 refrains from practices that are not permitted by law.

Any director or collaborator who directly or indirectly receives gifts or benefits from customers not provided for by the cases allowed, are required to notify the Governing Body of Arca24 which will evaluate its appropriateness.

3.4. Suppliers

RELATIONS WITH SUPPLIERS
Arca24 requires its suppliers and collaborators to respect ethical principles corresponding to its own, considering this aspect of fundamental importance for the creation or continuation of a business relationship.

CHOICE OF SUPPLIER
The purchasing processes are based on the search for the maximum competitive advantage for Arca24, on the granting of equal opportunities for each supplier, to loyalty and impartiality.

In particular, collaborators and employees in these processes are required to:

not to preclude anyone in possession of the required requisites the possibility of competing for the stipulation of contracts, adopting in the choice the shortlist of candidates objective and documentable criteria;
ensure sufficient competition for each “tender”: any exceptions must be authorized and documented.

The selection of suppliers and the determination of the purchase conditions must be based on an objective assessment of quality, the price and the ability to provide and guarantee services of an adequate level.

For Arca24 are reference requirements:

the availability, appropriately documented, of means, including financial, organized structures, project skills and resources, know-how, etc .;
the existence and effective implementation of adequate company quality systems;

3.5. Authorities

RELATIONS WITH THE AUTHORITIES
The assumption of commitments with the Authorities is reserved exclusively to the responsible and authorized company functions.

Those who, in the context of their duties, find themselves legitimately having relations with the Authorities are responsible for check in advance, and with due diligence, that what is declared or certified is true and correct.

For the same reason, it is necessary that the documentation that summarizes the procedures through which Arca24 is collected and stored came into contact with the authorities.

Arca24 through its employees or representatives must not promise or offer public officials or employees in general payments or goods to favor their interests.

Arca24 prohibits any form of gift directed specifically to public officials or their family members, which could affect independence of judgment or induce to ensure any advantage to Arca24. This rule does not admit exceptions even in those countries where offering gifts of value to business partners is customary.

Any employee who directly or indirectly receives proposed benefits from public officials or employees in general of the public authority must immediately report it to the Company.

CORRECT INFORMATION TO THE INSTITUTIONS
Any relationship with Swiss or international institutions is exclusively attributable to forms of communication aimed at evaluating implications of the legislative and administrative activity towards Arca24, to respond to informal requests or to acts of union inspection (interrogations, interpellations), or in any case to make known the position on issues relevant to Arca24. To this end, Arca24 is committed to:

establish, without any kind of discrimination, stable channels of communication with institutional interlocutors at the level international, community and territorial;
represent the interests and positions of Arca24 in a transparent, rigorous and coherent manner, avoiding the attitudes of naturecollusive.

Furthermore, Arca24 prohibits employees, top managers, consultants of the company and third parties from:

falsify and / or alter the reports in order to obtain an undue advantage or any other benefit for the company.
falsify and / or alter documentary data in order to obtain the favor or approval of a project that does not comply with the regulations in force on the matter.

3.6. Community

RELATIONS WITH PARTIES, TRADE UNION ORGANIZATIONS AND ASSOCIATIONS
Arca24 refrains from any direct or indirect pressure on politicians.

Arca24 does not finance parties in Switzerland or abroad, their representatives or candidates, nor does it sponsor congresses and parties that have an exclusive purpose of political propaganda.

It is possible to cooperate, even financially, with political-trade union organizations, for specific projects based on objective criteria and identified:

purposes related to the corporate mission and / or consistent with the ethical principles of reference;
clear and documentable destination of resources;
express authorization by the functions responsible for managing these relationships within Arca24.

CONTRIBUTIONS AND SPONSORSHIPS
Arca24 chooses to accept requests for contributions within the limit of proposals from organizations or associations that are declared without purpose for profit and with regular statutes and articles of incorporation, which are of high cultural or beneficial value. Sponsorship activities can that concern the issues of social, environmental, sport, entertainment and art, are intended only for events that offer a guarantee of quality or for which Arca24 can collaborate in the design, in order to guarantee originality and effectiveness.

In any case, when choosing the proposals to join, Arca24 pays attention to every possible form of conflict of interest in order personal or corporate.

RELATIONS WITH THE MEDIA
Consistent with the principles of transparency and completeness of information, Arca24’s communication to the outside is based on respect for the right to information. In no case Arca24 lends itself to disclosing false or biased news or comments.

Any type of communication must comply with the law, practices and rules of professional conduct and must be carried out in compliance with clarity and transparency.

4. Improvement goals

Below are listed the improvement objectives that Arca24 undertakes to respect in the coming years, in order to always have one greater attention and care towards its stakeholders.

INVOLVEMENT OF STAKEHOLDERS
Arca 24 is committed to the continuous development of the stakeholder engagement plan by improving its monitoring and collection of feedback generated by listening.

COLLABORATORS
Arca24 undertakes to update and establish, in agreement with its collaborators, the social and environmental objectives and targets individual or group.

DIVERSITY AND INCLUSION
Arca24 is committed to improving its performance relating to the theme of diversity and inclusion. Furthermore, Arca24 is committed to promote work life balance initiatives, inclusion and enhancement of diversity aimed at guaranteeing a work environment heterogeneous and comfortable.