By forwarding the completed form the subscriber declares to have read, understood and accepted all the following GENERAL CONDITIONS:

 

1)  LOCATION
The Educational Training will take place in the location indicated in the program or on an online platform provided by CRES.

 

2)  FULFILMENT OF THE CONTRACT
The present contract will be fulfilled when the CRES company will have a correctly completed form in all its parts and when proof of bank transfer is presented to CRES in a way that complies with art. 4 as it will be explained subsequently.
To maintain a high quality of the training course and the extracurricular activities provided by the Educational Training, all the courses will enrol a limited number of participants. The right of enrolment will be established on the basis of the date of submission of the request, the correct completion of the form and the proof of payment. Transfer – bonifico

 

3)  SUBSCRIPTION FEES
The subscription fees give the right to attend the Educational Training, to receive the support materials, and where specified to a work breakfast.
The fees indicated are all VAT excluded. The participants that have already taken part in other Educational Training provided by CRES will receive a 5% discount on the course fees. This discount cannot be used in conjunction with any other offer.
All the subscriptions received at least 30 days before the date when the Educational Course is due to start will receive a 5% discount on the total of the fees. This discount cannot be used in conjunction with other offer, unless specified in the brochure.

 

 

4)  PAYMENT PROCEDURE
With the only exception of the condition described in section 4b, a single payment needs to be completed at the time of the course subscription to CRES
For the Educational Training lasting 40 hours it can be arranged to have 2 equal payment instead of a single 1, this will be arranged and authorised at CRES discretions.
When paying the fees the participant need to include their Full Name, Job Title and the code of the Educational Training they are participating. The payment need to be made by bank transfer to Clinical Research Educational Services Srl, c/c 000103743325 – ABI 02008 – CAB 05142 – IBAN IT 63 I 02008 05089 000103743325–UNICREDITBANCA DI ROMA LAURENTINA – N. AGENZIA 00736 – VIA SIMONE MARTINI 14 – 00142 – ROMA

 

5)  CHANGES TO THE PROGRAMME 
CRES, reserves the right to cancel or reschedule the courses. This will be communicated to the participants by email. Any change will be communicated within 5 days prior the star of the Educational Training.
In case of a cancellation CRES will refund the subscription fees in full within 60 days from the date of the communication.
CRES reserves the right to modify the date and time of the course, and the course program without modifying the main objectives of the course itself. In addition CRES reserves the right to change the tutors and speakers in case of unforeseeable reasons.

 

6)  INABILITY TO PARTICIPATE (CANCELLATION OF ATTENDANCE)
A subscriber (only physical person) who cannot attend the course for a VALID REASON, will be offered attendance to the same Educational Course at a later date wherever possible or the participant can attend a different course of the same monetary value.

 

For a Corporate subscription, it is possible to change the registered attendee with a different person provided the new attendee is affiliated with the same company as the cancelled participation. Cancellation will not be eligible for total or partial reimbursement under any circumstance

 

 

7)  CONTRACT WITHDRAWAL
Individual and Corporate participants have the right cancel the contract by communicating it at least in 15 calendar days prior to the start of the Educational Training. The intention to cancel needs to be communicated by email first, which will be followed by a registered letter addressed to: Clinical Research Educational Services, via Pinerolo 2, 00182
It is also possible to rescind the contract at least 5 calendar days prior to the start of the course. This cancellation will result in a 50% charge of the total of the cost for the Educational Training.         

 

In case of art 7a/7b will take place CRES will reimburse the total (art 7a) or 50% (art 7b) of the cost within 60 days from the day the cancellation request is submitted.

d.In case the cancellation is submitted violating the parameters indicate in art.7a and art.7b, CRES is reserving the rights to withholds the entirety of the payment already submitted.

 

PARTICIPANTS RESPONSIBILITIES
Participants to the Educational Training are responsible for any damage caused to the structure, classroom, all the support material and any person present in the building where the course is taking place. They are also bound to respect the internal code of practice in relation to signing in, badges, safety procedures and any other code that may apply.

 

9)  CERTIFICATE  
A certificate of attendance will be issued at the end of the Educational Training to those participants whom attended at least the 80% of the course and are compliant with all the administrative requirements .

 

10)  INTELLECTUAL PROPERTY
All the materials provided will only to be used for the duration of the course and it will exclusively remain property of CRES or the Authors as regulated by the copyright rules and regulation.
All participants will comply tom the above mentioned copyright regulations by agreeing not to publish, modify or express any prejudice directly or indirectly to the intellectual property of the authors.

 

11)  PRIVACY
All the information submitted to CRES will meet the European legal requirements in relation to the data protection act described in the privacy policy.

 

il cliente può esercitare    i    diritti    di    cui    al    Codice    privacy    inviando    una    mail    all’indirizzo

…………………………………

12)  TELEMATIC SUBMITION AND DECLARETION OF CONFORMITY OF THE ORIGINAL FORM
in case of the use of electronic signature the candidate is happy that the copy send to CRES is in accordance with the original one.
13)  APPLICABLE LAW AND DISPUTE
The contract will be exclusively regulated by the Italian laws. For any dispute Foro di Roma will be the only Forum usable. The D.lgs. 6 September 2005, n. 206 will be applied only in case of subscription from a physical person unrelated to commercial and or professional activities

 

 

DATE                                                                                           SIGNATURE (whit stamp if company)

 

For the specific approval in relation to artt. 1341 e 1342 cod. civ. Of what is included in the art. 4) Payment procedure; 5) Change tot the program; 6) Inability to participate ; 7) Contract withdrawal ; 8) Participant responsibilities; 10) Intellectual property ; 11) Privacy; 12) Applicable laws and disputes , releted to “General Conditions”.

 

PRIVACY POLICY

WEB

CRES Srl

 

Information on the Processing of Personal Data pursuant to Art. 13-14 EU Regulation 679/2016

 

The company Clinical Research and Services S.r.l. – CRES S.r.l. (hereinafter referred to as “CRES S.r.l.”) in its capacity as joint controller of your personal data, pursuant to Art. 13-14 of EU Reg. 679/2016 (hereinafter referred to as “Regulation” or “GDPR”), and Legislative Decree 196/2003 and subsequent amendments and additions (Italian Privacy Code), hereby informs you that the aforementioned regulations provide for the protection of the parties concerned in the processing of personal data and that such processing will be based on principles of lawfulness, fairness, transparency and general protection of your confidentiality and  personal rights. For this purpose, CRES S.r.l. provides you with the following information on the processing of your personal data, while browsing our website as a  user or business reference contact requesting consulting services from CRES.

 

1. Identity and contact details of the Data Controller

Pursuant to Art. 4, 24 and 26 of the GDPR, the joint controllers are CRES S.r.l., in the person of its legal representative, Dr. Integlia, with registered office in Via Pinerolo, 2, 00182 ROME (RM), Tax Identification Number/VAT number 13378021003, Tel. +39 3509408889, email info@cres-italy.com and ISHEO S.r.l., in the in the person of its legal representative, Dr. Integlia, with registered office in Via Pinerolo, 2, 00182 ROME (RM), Tax Identification Number/VAT number 12127201007, Tel. +39 3313867522, email info@isheo.com

The rights identified below can be exercised by written communication to be sent to our Data Protection Officer Dr. Gjoka by e-mail to the following email address: dpo@isheo.com or dpo@cres.com or by registered letter with return receipt to the registered office address as indicated above.

 

2. Categories of personal data processed

According to the provisions of Article 14 of the Regulation, since personal data have not been obtained from the party concerned, the categories of data being processed are reported by CRES S.r.l. as follows:

• identification data (name, surname, email address, tel., etc.), as well as, in the case of communications or requests sent via the website, any further personal data that may be included in your message or in any other communication sent by you;
• data relating to sending a curriculum vitae;
• data relating to the activity and the performance of the services requested by you (name, surname, date of birth, document, etc.);
• any data needed for the fulfillment of legal obligations (such as, for example, your contact details for communications required by law or by the Authority).

3. Purpose and legal basis of data processing

Your personal data will be processed, in compliance with current regulations, in a correct, lawful and transparent manner for the purposes indicated below and according to the following conditions of lawfulness:

3.1 Management of your requests and/or communications

• The processing of your personal data will take place in order to correctly and effectively manage your request or communication sent by using the website contact details or by means of the “Contact Form” (Article 6.1.b, GDPR)
• Customer Management.

3.2  Execution of a contract or management of the pre-contractual relationship, including the provision of a service

• The processing of your personal data for this purpose is required for the execution of a contract or for the execution of pre-contractual measures

(here meant as a “legal relationship” established between you and the Data Controller following your request) (Art. 6.1.b, GDPR).

• Technical and functional access to the website whose technical cookies remain on the user’s device after the web browser has been closed.

3.3 Fulfilment of legal obligations (Article 6.1.c GDPR)

Once the contractual relationship has been established, the processing of your personal data is aimed at:

–  fulfilment of regulatory tax obligations

–  fulfilment of regulatory administrative-accounting obligations

–  fulfilment of regulatory obligations in the field of work and health

–  fulfilment of regulatory obligations deriving from the contract or from the legal

relationships of which you are a party concerned.

3.4 Marketing purposes

Only with your prior consent your data will be processed for promotional and marketing purposes as well as for statistical information relating the use of services (most visited pages, number of visitors per time or day, geographical location).

4. Data Processing Methods

We inform you that your data will be processed with the support of the following                     means/methods:

On a mixed basis – electronic and paper-based means.

• by electronic calculators with the use of software systems managed by third parties
• by electronic calculators with the use of software systems managed directly by the Owner.

For relevant communications we will use the data needed for remote communications  (for example: e-mail account, telephone, text message, etc.). On this point, CRES Sr.l. adopts adequate technical and organizational measures, aimed at effectively implementing the principles of data protection and integrating in the processing the necessary guarantees to meet the requirements of the Regulation and protect the rights of the parties concerned. Moreover, the Data Controller adopts adequate technical and organizational measures to ensure that, by default, only the personal data that are necessary for fulfilling specific processing purposes are processed.

5. Scope of communication and dissemination of personal data

For the purposes indicated above, your personal data may be disclosed:

• to the persons authorized by the Joint Controllers to carry out personal data processing operations (employees or parasubordinate collaborators of the Joint Controllers) in performing their duties;
• to external data processors, identified in writing and to whom specific written instructions have been provided on the data processing (including, for example, IT, technological and telematic service providers);
• to tax authorities, police and judicial and administrative authorities, in compliance with the law, for the detection and prosecution of crimes, prevention and protection from threats to public security, to allow the Joint Controllers to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others;
• to all natural persons and/or legal entities, both public and/or private, when the communication is necessary or functional to the performance of our business and in the manner and for the purposes illustrated above.

No dissemination of your data is envisaged.

6. Mandatory or optional nature of providing personal data

The provision of your personal data is not mandatory, but any objection might make it impossible for us to provide the services you requested.

7. Data retention period

We point out that, in compliance with the principles of lawfulness, purpose limitation and data minimization, pursuant to Art. 5 of the GDPR, we keep your personal data for a limited period of time, depending on the purpose of the processing. After this period, your data will be permanently deleted or in any case made irreversibly anonymous.

Your personal data will be stored in compliance with the terms and criteria specified below:

• for the management of your requests for a maximum period of 6 (six) months from the correct and complete management of your request;
• for the fulfillment of legal obligations for a maximum period of 10 (ten) years starting from the end of the calendar year in which the Joint Controllers have fulfilled the legal obligations, in order to document and be able to demonstrate that they have been correctly carried out, in compliance with the law;
• for the execution and fulfillment of the contractual purposes and in any case for no longer than 10 years from the termination of the collaboration relationship;
• for a period of time not exceeding 5 years from the data collection for marketing purposes;
• and in any case for a period of time not exceeding the achievement of the purpose for which data were collected and processed and in compliance with the mandatory time limits established by law.

 

Except for the case where retention for a subsequent period is required for any disputes, requests from the competent authorities or in accordance with applicable law.

8. Transfer of personal data to recipients outside the EU/EE

Your personal data will not be transferred to non-EU third countries or to any other international organizations outside the European Union.

9. Data collection sources

• Data that you provide us through our website referred to this Privacy Policy;
• Web surfing data that we collect from our wesite through “cookies”.

 

As data subject you have the right to obtain, from the Joint Controllers access to your personal data, as well as  the right to rectification, erasure (“right to be forgotten”, taking into account the actual technical possibilities), restriction of processing, updating, data portability and objection to processing of personal data concerning you  at any time. Moreover, you can exercise all the rights deriving from Articles 15, 16, 17, 18, 19, 20, 21 and 22 of the GDPR.

 

10. Rights of the data subject pursuant to Art. 15, 16, 17, 18, 19, 20, 21 and 22 of EU Regulation 679/2016.
11. The data subject has the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him/her are being processed, even if they have not been recorded yet, and their communication in an intelligible form, as well as the right to lodge a complaint to the supervisory authority.
12. The data subject has the right to obtain indication:

• of the origin of the personal data;
• of the purposes and methods of processing;
• of the logic applied in case of treatment carried out with the aid of electronic instruments;
• of the identification details of the Data Controller, of the data processors and of the designated representatives pursuant to Article 5, Paragraph 2;
• of the subjects or categories of subjects to whom the personal data may be discloded or who may become aware of them as appointed representative in the State territory, as well as managers or authorized persons.

 

 12.1 The data subject has the right to obtain:

• 1) updating, rectification or, when required, integration of his/her personal data.
• 2) erasure, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
• the attestation certifying that the operations referred to in letters c.1) and c.2) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except for the case where this fulfillment proves to be impossible or implies the use of means manifestly disproportionate to the protected rights.

 12.2 The data subject has the right to object in whole or in part:

• on legitimate grounds, to processing of personal data concerning him/her, even though they are relevant to the purpose of their collection;
• the processing of personal data concerning him/her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.

 

Moreover, the data subject has the right to lodge a complaint with the competent supervisory authority in the State of his/her habitual residence, place of work or State where the alleged data protection infringement occurred.

12.3 Processing of data for purposes other than that for which they were collected

If the Joint Controllers intend to further process the personal data for purposes other than that for which they were collected, prior to further processing, CRES shall provide the data subject with information relating the other purposes and with any relevant further information as referred to in Art. 13, Paragraph 2 of the GDPR.

 

12. 4 Cookie management

A “cookie” is a text file that is stored on the user’s device when accessing a website with the aim of provinding information every time the user visits the website. It is a sort of reminder of the Internet page that has been visited. Through cookies, the web server sends information to the user’s browser (Internet Explorer, Mozilla, Google Chrome, Firefox, etc.), stored on the user’s device, which will be re-read and updated every time the user returns to the website. This way the website can automatically adapt itself to the user’s needs and preferences.

While browsing the website, the user may also receive on his/her device cookies from different websites, the so-called third-party cookies, set directly by the website managers and used for purposes and in the manner defined by them.

Depending on their duration, they are divided into session cookies or temporary cookies − that are automatically deleted from the user’s device at the end of the browsing session by closing the browser ­− and persistent cookies or cookies stored on the device until their expiration or cancellation by the user.

Based on the function and purpose of use, cookies can be divided into technical cookies and profiling cookies.

 

• Technical cookies

Some cookies are used for electronic authentication, monitoring of sessions and storage of specific information regarding user’s activities when accessing a web page. These cookies are known as technical cookies and are often useful to allow users to browse a website and to use all its functionalities. Technical cookies are cookies whose use does not require the user’s consent. Analytical cookies also belong to this category. These  cookies collect information about how users access a website and allow improving its functioning. For example, analytical cookies show which pages are most frequently visited, allow web developers to study the recurring patterns of use of a website and help them understand any difficulties users are experiencing in browsing the website.

 

• Profiling cookies

Profiling cookies are used to monitor and profile users while browsing, record their web browsing activities or consumption habits (what they buy, what they read, etc.), also for advertising purposes aimed at targeted and customized services. The use of these cookies requires the prior acquisition of the user’s free informed consent, pursuant to Art. 7 of EU Regulation 679/2016 and to the national legislation in force.

 

• Third party cookies

It may happen that a web page includes cookies from other websites contained in various elements hosted on the page itself, such as advertising banners, images, videos, maps or specific links to web pages of other domains residing on servers other than the one on which the requested web page is located. In other words, these cookies are set directly by the website managers or by servers other than this website.

In these cases, we are talking about the so-called third-party cookies, which are usually used for profiling purposes. The use of these cookies requires the prior acquisition of the user’s free and informed consent.

 

• Types of cookies used in our website

We remind you that, proceeding with the browsing of this website, or closing the cookie information banner, by clicking on the “Accept all” and X buttons (top right), implies the persistence of the default settings and therefore the browsing in the absence of cookies or other tracking tools other than technical cookies.

There are wo types of cookies: session cookies and persistent cookies.

As defined above, session cookies are temporary cookies that remain on the device until you leave the website; “persistent cookies” remain on your device for much longer or until they are manually deleted.

The main functions of the cookies installed by www.cres.isheonline.com are technical, used to constantly improve its services, and for authentication and statistical purposes, such as counting the number of website visitors. Without technical cookies, which are strictly necessary, a website could not provide any service and  would not be as smooth and easy as it should be. The use of cookies is therefore strictly aimed at facilitating the server functions while browsing the website. Below you can find the list of the specific cookies we use.

 

• Strictly Necessary Technical Cookies

 

This website is built on the WordPress and, therefore, it uses the cookies implemented by the aforementioned platform and others.

The cookies used are the following:

 

Name	Duration	First-party cookies or third-party cookies	Third-party links
CookieConsent	1 year	Third-party cookies	https://www.cookiebot.com/en/cookie-declaration/
_wpfuuid	11 months	Third-party cookies	Registers a unique ID for the visitor in order for the website to recognize the visitor upon re-entry.
CONSENT	2 years	Third-party cookies	https://www.cookiebot.com/en/cookie-declaration/
wp-wpml_current_language	Session cookies	Third-party cookies	https://wpml.org/documentation/privacy-policy-and-gdpr-compliance/

 

• Profiling cookies (advertisement) and other cookies

 

Name	Duration	First-party cookies or third-party cookies	Third-party links
yt-remote-connected-device	Session cookies	Third-party cookies	https://policies.google.com/technologies/cookies?hl=it
yt-remote-device-id	Session cookies	Third-party cookies	https://policies.google.com/technologies/cookies ?hl=it
VISITOR_INFO_LIVE	5 months e 27 days	Third-party cookies	https://policies.google.com/technologies/cookies ?hl=it
YSC	Session cookies	Third-party cookies	https://policies.google.com/technologies/cookies?hl=it
VISITOR_INFO1_LIVE	179 days	Third-party cookies	https://policies.google.com/technologies/cookies?hl=it
yt-remote-device-id	Persistent cookies	Third-party cookies	https://policies.google.com/technologies/cookies?hl=it
yt-remote-connected-devices	Persistent cookies	Third-party cookies	https://policies.google.com/technologies/cookies?hl=it
yt-remote-session-app	Session cookies	Third-party cookies	https://policies.google.com/technologies/cookies?hl=it
yt-remote-cast-installed	Session cookies	Third-party cookies	https://policies.google.com/technologies/cookies?hl=it
yt-remote-session-name	Session cookies	Third-party cookies	https://policies.google.com/technologies/cookies?hl=it
yt-remote-cast-available	Session cookies	Third-party cookies	https://policies.google.com/technologies/cookies?hl=it
yt-remote-fast-check-period	Session cookies	Third-party cookies	https://policies.google.com/technologies/cookies?hl=it

 

We remind you that, if you do not accept cookies or disable them, this could affect your user experience while browsing our website.

Please note that our banner performs a monthly scan of the cookies present on the site, therefore, in the event that there is not a full correspondence of the cookies referred to in this policy please consider those specifically reflected in the banner of reference.

 

• Cookie Management

 

You can manage your own preferences relating to cookies by modifying your Internet browser settings and using the features that allow to delete, disable and block cookies (all or some), or limit them to specific websites.

Therefore, you can disable cookies by following the deactivation procedure provided by your browser. Please find below the procedures proposed by the main Internet browsers: Microsoft Windows Explorer, Mozilla Firefox, Google Chrome, Apple Safari, Google Analytics,  by downloading a specific browser plug-in.

To get information on the cookies stored on your device and disable them individually, please go to the following link: http://www.youronlinechoices.com/it/le-tue-scelte.

 

13- Privacy Policy Amendments

 

The evolving nature of our activities and possible regulatory interventions on the subject may require changes in the procedures for processing of your personal data described so far. This Privacy Policy may therefore undergo amendments and additions over time.

The updated version of this Privacy Policy will be published on this web page with the indication of the date of its last update. We therefore invite you to consult this page when accessing the website.

 

 

Last updated April 15, 2022

 

ISHEO S.r.l.

CODE OF ETHICS

 

Summary

 

ISHEO S.R.L. VISION STATEMENT ……………………………………… …………………………………….. 3

PURPOSES AND RECIPIENTS ……………………………………….. ……………………………………. 3

1 GENERAL PRINCIPLES ……………………………………….. ………………………………………….. … 3

1.1 Legality ………………………………………… ………………………………………….. …………… 3

1.2 Fairness ………………………………………… ………………………………………….. ……… 4

1.3 Non-Discrimination ……………………………………….. ………………………………………. 4

1.4 Meritocracy ………………………………………… ………………………………………….. …….. 4

1.5 Confidentiality ………………………………………… ………………………………………….. …… 4

1.6 Diligence ………………………………………… ………………………………………….. ………… 5

1.7 Loyalty ………………………………………… ………………………………………….. …………….. 5

2 RELATIONS WITH EMPLOYEES AND COLLABORATORS ……………………………….. 5

2.1 Personnel Selection ………………………………………. ………………………………….. 5

2.2 Personnel Management ………………………………………. ……………………………………. 5

3 WORKPLACE HEALTH AND SAFETY …………………………………….. ………………… 6

4 COMPANY MANAGEMENT ……………………………………….. …………………………………… 6

4.1 Compliance with Internal Procedures ……………………………………… …………………… 6

4.2 Accounting Management ……………………………………….. …………………………………………. 7

4.3 Asset Protection ………………………………………. ………………………………………. 7

4.4 Communication ………………………………………… ………………………………………….. … 7

5 RELATIONS WITH EXTERNAL ENTITIES……………………………………….. …………………………………. 7

5.1 Relations with Authorities and Public Administrations ……………………………………. …. 7

5.2 Relations with Customers and Suppliers …………………………………….. ……………………………. 8

6 INTERNAL CONTROL SYSTEM ……………………………………… ……………………….. 8

7 PENALTY SYSTEM GUIDELINES …………………………………….. ………….. 8

 

 

FOREWORD

ISHEO S.R.L. VISION STATEMENT

 

ISHEO S.r.l. is aware that the authority of a company can be measured by the competence of its collaborators, by the high quality of the service provided to customers and by the ability to create an ethically healthy environment based on fairness, respect, loyalty and encouragement of talent and merit.

The principles that inspire the work of this Company have been formally collected in a Code of Ethics and Business Conduct in the belief that the company’s reliability and prestige is built day by day respecting the rules and giving value to people.

This Code of Ethics therefore represents an important distinctive and identifying element towards the market and third parties, the knowledge and sharing of which is required of all those who operate in the Company or collaborate with it in any capacity. It constitutes the foundation of our business and an indispensable step for the achievement of our mission.

 

PURPOSES AND RECIPIENTS

This Code of Ethics (hereinafter referred to as the “Code”) contains the set of ethical and moral principles that inspire and guide the activity of ISHEO S.r.l. (hereinafter referred to as the “Company”) as well as the lines of conduct adopted by the Company both in the relations with employees and with external subjects and entities such as institutions, suppliers, customers, business partners, etc.

The observance of these principles is a priority to accomplish of ISHEO corporate mission and to ensure that it maintains its reputation in the socio-economic context in which it operates.

The present Code is therefore binding on ISHEO management and employees, as well as for all those who work and collaborate with the company, on a permanent or fixed-term basis (hereinafter referred to as “Recipients”).

The Code will be disseminated not only inside the company but also outside it, above all through its website.

 

1 GENERAL PRINCIPLES

The conduct of the Recipients, at all company levels, shall comply with the principles of legality, fairness, non-discrimination, meritocracy, confidentiality, diligence, and loyalty.

 

1.1 Legality

ISHEO operates in accordance with the laws in force and with the present Code.

All Recipients are therefore required to comply with all applicable regulations and to constantly be updated on legislative developments.

 

1.2 Fairness

Recipients are required to inspire their conduct on the principle of fairness.

Therefore, Recipients, in carrying out their activities, are required not to establish any privileged relations with third parties aimed at obtaining improper advantages and to not accept gifts or any other kind of benefit (except gifts of modest value or business courtesies) that could improperly grant advantages to third parties.

On their turn, Recipients are prohibited from making donations of money or offer gifts or favors of any kind to third parties (except gifts of modest value or business courtesies authorized by the Company) in connection with the activities performed by them for the benefit of ISHEO.

 

1.3 Non-Discrimination

In the personnel selection and management, in the organization of the working activities, in the choice, selection and management of suppliers, as well as in relations with entities, institutions and customers, ISHEO rejects any form of discrimination based on age, sex, race, sexual orientation, health conditions, political opinions, religion, culture and nationality of its interlocutors.

ISHEO is firmly convinced that wealth lies in diversity, and it is committed to encouraging integration through the promotion of intercultural dialogue and protection of the rights of minorities and weakest subjects.

 

1.4 Meritocracy

Personnel selection and management and work organization, at all levels, are based on the recognition of merit as a method to access rewards and improve one’s own professional status.

 

1.5 Confidentiality

ISHEO commits itself to ensure the protection and confidentiality of the personal data of which it gains knowledge in carrying out its business activities, in compliance with all national and/or EU regulations applicable to the protection of personal data.

Recipients are required to treat any information or data acquired during the execution of their work activities as confidential, to not disclose them for purposes not related to such activities, and in any case to always act in compliance with the confidentiality obligations undertaken by ISHEO. Particularly, Recipients are required to assure the utmost confidentiality and inaccessibility to third parties on documents relating know-how, transport information, business information and corporate operations.

 

1.6 Diligence

The relationship between ISHEO and its employees is based on mutual trust. Employees are required to work to promote the interests of the company, in conformity with the ethical values set forth by the present Code of Ethics, and to refrain from any activity that could constitute a conflict of interest with the interests of ISHEO.  Any direct or potential conflicts of interest that may arise, must be promptly reported to the Management to evaluate case-by-case their existence and severity and to avoid or mitigate the relevant consequences.

In case of violation, the Company will take all appropriate measures to remove the conflict of interest, reserving the right to act for its own protection.

 

1.7 Loyalty

ISHEO undertakes to conduct its activities, within a framework of fair competition, in accordance with current national and EU legislation, in the awareness that virtuous competition stimulates innovation and the development, producing benefits for the entire Community.

 

2 RELATIONS WITH EMPLOYEES AND COLLABORATORS

2.1 Personnel Selection

The Personnel assessment and selection are based on the principles of fairness, transparency, and equal opportunities in order to combine the needs of ISHEO with the candidate’s professional profiles, ambitions, wishes and expectations.

ISHEO undertakes to manage the personnel selection procedures so as to avoid any form of favoritism, using objective and merit-based criteria, respecting the dignity of the candidates in the view of the company success.

ISHEO undertakes to provide hired personnel with clear and correct information as regards roles, mutual responsibilities, rights, and duties.

 

2.2 Personnel Management

ISHEO protects and makes the most of its human resources, committing itself to ensuring a context that favors professional growth, knowledge, and skills of each person. ISHEO rejects any form of top-down management of personnel recognizing, on the contrary, that a horizontal approach based on participatory tools that allow to gather opinions, suggestions, and the widest participation of its resources, ensures greater benefits to people and company organization.

Without prejudice to the maximum availability towards the Company, no employee can be forced to perform duties, services or favors not due under his/her employment contract and his/her role within the company.

The Company is firmly committed to prevent and combat episodes of mobbing, stalking, psychological violence, and any discriminatory or harmful behavior that violates a person’s dignity inside and outside the business premises.

Relations between employees must be conducted with loyalty, fairness, and mutual respect, in compliance with the values of civil coexistence and freedom of people.

 

2.3 Conflict of Interest

ISHEO employees or consultants are required to inform in writing the legal representative of any, direct or indirect, relations, paid in any form, they had in the last three years, with private subjects that can even also abstractly influence or compromise professional judgement and objectivity in the performance of their tasks.

Any kind of interest can raise a potential conflict, including non-financial ones.

 

3 WORKPLACE HEALTH AND SAFETY

ISHEO is committed to ensuring its staff a work environment based on health, safety, and respect of the dignity of workers.

Workplace safety is ensured both by strictly implementing the provisions provided for by the laws in force and by actively promoting a culture of safety.

 

4 BUSINESS MANAGEMENT

4.1 Compliance with Internal Procedures

ISHEO believes that management efficiency is essential for achieving its objectives. Without prejudice to the company’s willingness to evaluate any improvement of the procedures proposed by the staff, this latter is required to strictly observe the company’s internal procedures and instructions.

Recipients must act according to their respective authorization profiles and must keep any suitable documentation to keep track of the actions taken on behalf of the company.

 

4.2 Accounting Management

In the accounting management activity, Recipients are required to act in compliance with the principles of truthfulness, accuracy, and transparency, so that the reputation of ISHEO is protected both internally that externally. The observance of these principles also allows the company to define its own operational strategies based on its actual economic and financial situation.

All the accounting items must therefore be supported by a complete, clear, and valid documentation, avoiding any form of omission, falsification and/or irregularity.

In case of economic or financial elements based on evaluations and estimates, the relating recording must be inspired by criteria of reasonableness and prudence.

 

4.3 Asset Protection

Recipients must carry out their activities inspired by a rational and efficient use of the business resources. Recipients are required to comply with safety provisions, to protect hardware from unauthorized access, which could seriously damage the right to the protection of personal data concerning ISHEO’s staff and customers.

 

4.4 Communication

ISHEO promotes an effective corporate communication that make it possible to establish contacts with the civil society, in order to acknowledge the Community demands and needs and to disseminate the company’s values and mission.

ISHEO’s advertising promotion respects ethical values, protecting minors and repudiating vulgar or offensive messages.

 

5 RELATIONS WITH EXTERNAL ENTITIES

 

5.1 Relations with Authorities and Public Administrations

Relations with Authorities and Public Administration must be based on the maximum clarity, transparency, and collaboration, in the strictest observance of laws and regulations and according to the highest moral and professional standards.

In relations with Public Officials, Public Service Officers and Public Administration in general, the authorized Recipients must comply with the highest levels of fairness e integrity, refraining from any form of explicit or veiled pressure aimed at obtaining any undue advantages for themselves or for ISHEO.

 

5.2 Relations with Customers and Suppliers

ISHEO undertakes to not provide its services in favor of direct competitors in the same timeframe in relation to a specific product or service.

Recipients are required to interact with customers and suppliers in a competent, professional, and polite manner, in the awareness that the protection of the image and of the reputation of the company and, consequently the achievement of company objectives, depends also on their ability to deal with third parties.

Recipients are required to make every effort to offer timely and high-quality services to customers.

Relations with suppliers are based on loyalty, fairness, and transparency.

The choice of suppliers is be made on the basis of objective suitableness and cost-effective criteria.

It is forbidden to choose suppliers on the basis of purely subjective and personal grounds or, in any case, by virtue of interests conflicting with those of the company.

Recipients must put in place every possible control measure to ascertain that also customers and suppliers comply with the fundamental ethical principles set out in the present Code of Ethics.

It is forbidden, in the relationship with third parties, to ask or solicit, in any way, payments, gifts or other benefits, for oneself or for others, except for those of modest value occasionally offered within the scope of normal courtesy relations and in the context of international customs. The modest value must not exceed € 150.00.

In any case, it is forbidden to accept gifts in the form of money, for whatever amount.

The company annually organizes anti-corruption courses for its employees.

 

6 INTERNAL CONTROL SYSTEM

Compliance with the provisions of this Code of Ethics is entrusted to prudent, reasonable, and careful supervision of each of Recipients within their respective roles and functions within the company. ISHEO shall adopt all the measures needed to bring the infringement to an end, having authority to take any disciplinary measures in compliance with the law and workers’ rights.

 

7 PENALTY SYSTEM GUIDELINES

Violation of the principles set out in the Code of Ethics and in the procedures indicated in internal controls compromises the fiduciary relationship between the Company and its directors, employees, consultants, collaborators in various capacities, customers, suppliers, commercial and financial partners.

Such violations will therefore be immediately prosecuted by ISHEO in an effective and timely manner, through the adoption of adequate and proportionate disciplinary measures.

Violation of the rules of the Code of Ethics constitutes:

◦ serious breach for employees (workers, employees, managers) that can result in sanctions, applied, on a severity scale, according to the provisions of the National Collective Labor Agreement for each specific category. In the case of pending criminal proceeding or execution of a measure restricting personal freedom relating an employee, before adopting the disciplinary measure, the suspension from work without pay can be adopted, for the duration corresponding to the outcome of the prosecution or until the end of the measure restricting personal freedom;

◦ cause of immediate termination of the work relationship, in the case of serious infringements, for external collaborators e parasubordinates;

◦ cause of immediate termination of the work relationship, in the case of serious infringements, for suppliers, contractors and subcontractors.

The identification and application of sanctions shall always take into account the general principles of proportionality and adequacy with respect to the alleged violation.

In all the above cases, ISHEO also retains the right to exercise all the actions it deems appropriate for compensation for the damage suffered as a result of the violation of the Code of Ethics.