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What is the Code of Ethics?


The Code of Ethics is a document approved by the Board of Directors of Spindox S.p.A. (hereinafter only “Spindox” or “Company”) that contains the fundamental principles regarding the ethical and professional conduct that influence the activities and decisions at Spindox.

The Code of Ethics also regards the principles of conduct that make it possible to prevent the crimes referred to in Legislative Decree 231/2001 and must, therefore, be considered an integral part of the Organization, Management, and Control Model pursuant to Legislative Decree 231/2001 and a fundamental tool for achieving the objectives of the latter.

Who does the Code of Ethics apply to?

The Code of Ethics applies to all members of the Board of Directors, directors, managers, employees, collaborators, and other persons or companies acting in the name and on behalf of Spindox as well as to companies of which Spindox holds shares. Spindox endeavors to ensure that the Code of Ethics is considered a reference point for conduct in business also by those with whom Spindox maintains business relations, such as consultants, suppliers, contractors/subcontractors, customers, brokers, and intermediaries.

How can one become informed about the Code of Ethics?

The Company promotes training initiatives and programs to ensure the awareness and communication of the Code of Ethics and the proper understanding of the Code of Ethics internally as well as the awareness on the part of the recipients of the need for and value of working with the utmost correct behavior. Spindox also ensures the external communication of the Code of Ethics, providing the necessary interpretative support for the provisions contained therein to fully inform suppliers, contractors, subcontractors, and all other interlocutors, both private and institutional, about the values that the Code of Ethics intends to promote and, in general, the company policy that influences it.

Can the Code of Ethics be modified?

The Code of Ethics is subject to periodic review by the Spindox Board of Directors. The audit takes into account, among other aspects, the comments and suggestions received from the supervisory board, administrators, directors, managers, and employees, regarding regulatory changes and best practices, as well as the experience acquired in the application of the Code of Ethics itself. Any changes to the Code of Ethics introduced following this review are published and made available in the manner previously described.

Who we are

Spindox is a constantly expanding multinational company. Its mission is to support the innovation of its customers’ business by offering consultancy, information & communication technologies (ICT) services, technological solutions, and research support.

What we do

In line with its mission, Spindox operates in four areas:

  1. Business consultancy (strategy design, experience design, product/service design) and IT consultancy (governance, analysis, cybersecurity, compliance);
  2. ICT services (system integration, software development, application maintenance, operations support, help desk/service desk, network engineering, management of hardware and software infrastructures);
  3. Technology (software solutions);
  4. Research and discovery (prototyping/industrialization projects, identification of new products, extreme innovation).
  5. The objective of our business is to fully satisfy our clients’ needs and we believe in the establishment of a lasting collaboration characterized by fairness and transparency.

What we do

  • We evaluate the best solutions to ensure maximum customer satisfaction.
  • We are constantly searching for innovative services and products and we do this through research and experiments.
  • We are constantly searching for innovative services and products and we do this through research and experiments.
  • We offer services and products that are not only technically advanced but also ethically correct.
  • We provide accurate, honest, and comprehensive information about the services and products we offer to enable customers to make informed decisions.
  • We ensure adequate methods of communication, committing ourselves to acknowledging and considering suggestions and constructive feedback to develop a relationship built on trust.

What we don't do

  • We do not offer services and products that do not have concrete utility.
  • We do not use other people’s ideas nor innovations without authorization. Instead, we establish our own principles of open innovation.
  • We are against any acts of favoritism that could upset free competition.
  • We do not follow up on requests from clients who we believe may be in conflict with our ethical principles.
  • We do not use our nor our customers’ IT tools to conduct illegal practices or for purposes other than the proper execution of our work.

We are people

Spindox is made up of people. Only thanks to their human and professional contribution have we become who we are.

What we do

  • We select people who meet objective criteria based on merit, competence, and professionalism.
  • For us, everybody has equal rights and must have the same opportunities. We respect and value the diversity that is manifested through the personal ideas, culture, and values of each individual. We are open to different opinions and experiences without any prejudices.
  • We develop plans that ensure equal gender representation including the presence of women in positions of high responsibility.
  • We promote a collaborative work environment characterized by mutual respect.
  • We guarantee adequate working conditions and salary compensation proportional to the quantity and quality of the work performed, applying the provisions of the relevant National Collective Labor Agreement.
  • We firmly believe that work is a component of the life of each individual and take into account the continuous evolution of the work world.
  • We implement corporate welfare policies.
  • We promote agile and remote working (i.e. smart working), guaranteeing the right to balance work and leisure and, therefore, disconnect from technological equipment and IT work platforms.
  • We consider the competence and professionalism of our employees to be fundamental.
  • We promote training initiatives aimed at enhancing and increasing the skills of our people.
  • We ask from everyone commitment, dedication, fairness, and respect.
  • We believe in a healthy, safe, and secure workplace.
  • The health and safety of our people form the basis of all our choices; thus, we take the necessary actions to prevent risks that arise from our work activities.
  • We minimize our direct and indirect environmental impact through the continuous improvement of our environmental performance.
  • We believe in respecting the confidentiality of both our people and the information that is acquired when conducting our work activities.
  • We carefully handle tangible assets (e.g., telephones, computers) and intangible assets of the company (e.g., e-mail, software) and we do not use these assets for purposes unrelated to the company. Each employee is required to use the resources and information technology equipment of any nature appropriately, including the data contained therein and the information that can be obtained by them.
  • Our people adhere to the company rules that guide all their activities.
  • We observe and promote compliance with the laws enforced regarding the protection of the rights of adults and children (“human rights”) as fundamental and universal directives.

What we don't do

  • We do not give in to pressure and we do not practice favoritism, both of which do not benefit our growth.
  • We do not tolerate any kind of discrimination based on, for example, ethnicity or nationality, gender, religion, age, disability, sexual orientation, pregnancy, etc.
  • We do not tolerate retaliation against anyone who reports discriminatory behavior.
  • We do not tolerate any form of harassment, bullying, or offensive conduct.
  • We do not take advantage of employees by asking them to work beyond what is contractually established and without guaranteeing them adequate compensation.
  • We are not satisfied with offering our clients only sufficient service.
  • We cannot allow ourselves to be unprepared, as this would affect our reputation.
  • We do not do things we are not able to control.
  • We do not expose our employees to risks during the conduct of their work activities that could lead to accidents, emergencies, health problems, or security issues.
  • We do not disclose information about our staff or information obtained in the course of our work activities in the absence of demonstrated necessity.
  • We do not permit lending, selling, or donating without authorization.
  • Unencrypted data exchange (e.g., via e-mail or a USB stick) is not a secure means of communication.
  • We do not ask our employees to engage in unlawful conduct or conduct that is against company rules.
  • We reject any kind of exploitation of child labor, forced or compulsory, as well as any form of human trafficking and modern slavery. This is true not only within our company, but also in regard to the conduct to be adopted in relations with business partners.

We are not alone

During our business activities, we interact with various interlocutors. Our approach and ethics do not change towards them. We act with loyalty, correctness, integrity, and impartiality always in full compliance with the law.

What we do

  • We conduct business negotiations and carry out contractual relations based on fairness, loyalty, and professionalism.
  • We select suppliers (consultants, business partners, etc.) that meet objective criteria based on competence, reliability, professionalism, competition, and costs.
  • We conduct evaluations aimed at maintaining relations with reliable counterparties and high ethical standards. Each relationship with suppliers and collaborators adheres to the laws and regulations on labor, health and safety, environment, and anti-corruption, and each supplier must guarantee respect for fundamental human rights, the principles of equal treatment and non-discrimination, as well as the protection against child and forced labor.
  • When executing contracts, we require diligence, professionalism, loyalty, transparency, and confidentiality.
  • We bestow gifts only if they are symbolic or have such a value as not to undermine the independence of judgment of the recipient and not be interpreted as aimed at obtaining preferential treatment.
  • We maintain collaborative, fair, and transparent relations with representatives of the public administration.
  • We believe in the growth of socio-economic prosperity and to this end, we contribute to donations and patronage towards associations, schools, etc.
  • We strictly adhere to the legal requirements regarding financial reporting and regular accounting procedures.
  • We file tax returns to honestly reflect the Company’s financial performance.
  • We accept proceeds and make payments based on actual and justified transactions.
  • Integrity and honesty matter to us.
  • We use our own privileged information or information acquired from clients only for the correct execution of the work activity.
  • We protect the privacy and confidentiality of information, including that which we become aware of through our relationships with clients and third parties.

What we don't do

  • We do not offer or accept sums of money, gifts, entertainment, or other benefits to conclude a negotiation or to continue a contractual relationship.
  • We do not make decisions based on criteria that are not objective in a declared and transparent manner.
  • We do not undertake business initiatives with persons whose involvement in criminal organizations in stolen goods or money laundering or other types of illegal activities is known or suspected and we terminate the relationship if such practices should be ascertained during the effectuation of the relationship.
  • We do not tolerate the violation of the principles of legality, diligence, transparency, confidentiality, and respect for the dignity of people. Such violations are a just cause for the termination of contracts with suppliers.
  • We do not accept proposals of benefits from suppliers to favor their business.
  • We do not lend ourselves to corrupt practices, collusive behavior, nor illicit favoritism; therefore, we do not expect anything in return when we bestow a gift.
  • We do not inappropriately influence the decisions of the public administration by offering monetary compensation or other benefits, such as commercial or job opportunities, which can benefit public officials or persons in charge of public service, as well as their families or persons in any case indicated by them.
  • We do not use knowledge of information to obtain any kind of advantage or facilitation.
  • We condemn any conduct aimed at obtaining any type of contribution, financing, or other disbursements from the public administration through altered or falsified declarations and/or documents.
  • We do not grant contributions and donations without first verifying the destination of the donation and the coherence with our ethics.
  • Spindox’s relations with private entities, such as non-profit organizations, cannot in any way compromise its integrity and reputation.
  • We do not permit any inaccurate accounting documentation.
  • We do not modify or falsify information contained in any type of document.
  • We do not tolerate illegal practices aimed at hiding the real economic and financial performance of the Company.
  • We do not allow involvement in illegal practices, e.g., money laundering and terrorist financing.
  • We do not make decisions when we have a conflict of interest.
  • If one acquires “inside information” regarding Spindox or companies that do business with Spindox, this person is prohibited from engaging in stock transactions or any other transactions that take advantage of this information.
  • We do not disclose “inside information” to other people, such as friends or family, for them to benefit.

Who enforces compliance with the Code of Ethics?

Spindox has established a supervisory body pursuant to Legislative Decree 231/2001 that has the task of monitoring and supervising the implementation of the Organizational Model and the Code of Ethics by the recipients, including through the acceptance of reports and suggestions.

What happens if the Code of Ethics is not respected?

In the event the rules contained in this Code of Ethics are not respected, the offender will be subject to a penalty.


If the answer to any of these questions is “no” or even “maybe”:

  1. Contact your direct superior immediately. If your superior is the person who’s asking you about behaviour which does not comply with this Code of Ethics, don’t worry, but contact the Supervisory Board at the following e-mail address: spindox.reporting@gmail.com.
  2. If you suspect or become aware of an alleged breach of the Code of Ethics or other conduct improper for the Company, report it by writing, as above, to: spindox.reporting@gmail.com.

Access to the e-mail box spindox.reporting@gmail.com is permitted EXCLUSIVELY to the Chairman and Secretary of the Supervisory Board, qualified professionals NOT employees of Spindox spa. Therefore, your report will remain confidential and only known to external members of the Supervisory Board.

If you do not wish to use e-mail, you may send a letter in paper format, either by ordinary or registered mail, to the following address: Chairman of the Supervisory Board c/o Spindox S.p.A., via Bisceglie 76, 20152 Milan.

If your report contains personal data, these will be processed in accordance with the provisions of EU Reg. 679/2016 (GDPR) on the legal basis of “Legitimate interest of the Owner” following the principle of “minimization”, for your greater protection we remind you that the information communicated under a whistleblowing system must remain factual and have a direct connection with the subject of the report.