Open Impact Code of Ethics
Introduction
1.1 Purpose of the Code of Ethics
1.2 Recipients of the Code of Ethics
Under no circumstances may the pursuit of an interest or advantage for Open Impact be used to justify conduct that is inconsistent with the principles and standards set out in this document.
1.3 Contractual Value of the Code of Ethics
Any violation of the provisions of this Code of Ethics shall constitute a breach of the relationship of trust established with Open Impact and shall be sanctioned in a manner proportionate to the seriousness of the offence committed, without prejudice, for employees, to the procedures set out in the applicable National Collective Bargaining Agreements (CCNLs) and the Workers’ Statute (Law No. 300/1970).
Violations committed by third parties shall be sanctioned in accordance with the provisions of the specific contractual clauses (including express termination clauses and/or penalty clauses) included in agreements with such parties, to ensure their compliance with this Code of Ethics.
1.4 Commitment to the Implementation, Dissemination, and Updating of the Code of Ethics
The Code of Ethics is made known to all identified recipients. In particular, through its relevant internal functions, Open Impact is committed to ensuring the widest possible dissemination of the Code of Ethics among its employees and collaborators, in order to facilitate understanding of its guiding principles.
Open Impact ensures that all recipients and stakeholders are fully informed about the Code of Ethics and any subsequent updates, and that they are given access to any further information or clarification they may require.
To this end, Open Impact makes the Code fully accessible by using all appropriate means to ensure the broadest possible visibility and dissemination, including email communications, publication on its website, and references to the Code in the contractual clauses governing the employment of staff and the engagement of company consultants.
Open Impact is committed to updating the contents of the Code of Ethics in line with regulatory developments, carrying out appropriate investigations whenever reports of violations of its provisions arise, and applying the prescribed sanctions where such violations are confirmed.
1.5 Obligations of Open Impact Directors, Employees, and Collaborators
Directors, employees, and collaborators of Open Impact are required to be familiar with the principles and contents of this Code of Ethics, as well as with the laws, internal procedures, and internal regulations governing the activities carried out within their respective roles.
In particular, they are required to:
- Refrain from any conduct that is contrary to such laws, principles, procedures, and regulations;
- Seek guidance from their supervisors and the Board of Directors whenever clarification is required regarding their application;
- Promptly report to the Board of Directors any actual or suspected violations of the Code of Ethics, as well as any requests to engage in conduct that would violate it;
- Cooperate, where requested, in the investigation of any alleged violations;
- Adequately inform third parties of the existence of the Code of Ethics and of the commitments and obligations it imposes on external parties.
1.6 Core Ethical Principles
Open Impact’s objective is to embrace each individual in their entirety, fostering their overall personal and professional development through inclusive learning and training processes, thereby enabling them to generate social value through their professional contribution.
TRANSPARENCY
Sexual harassment is not tolerated, and any conduct or language that may offend an individual’s dignity or sensitivity must be avoided (for example, the display of sexually explicit images or persistent and repeated sexual remarks or innuendos).
Statement of Intent and Rules of Conduct Towards Third Parties
In accordance with the ethical principles set out above, Open Impact undertakes to:
- Prevent unlawful conduct: in keeping with its values of honesty and transparency, Open Impact is committed to implementing all necessary measures to prevent and avoid unlawful acts. In particular, it prohibits the payment of money or any other form of bribery intended to secure direct or indirect advantages for the Company. It also prohibits the acceptance of gifts or favors from third parties that go beyond customary standards of hospitality and courtesy;
- Avoid conflicts of interest: Open Impact does not allow its employees and collaborators to engage in relationships or situations that may give rise to conflicts of interest with their organizational role. This applies both where an employee or collaborator pursues interests that differ from the Company’s mission or personally benefits from business opportunities belonging to the Company, and where representatives of clients, suppliers, or public authorities act in breach of the fiduciary duties associated with their position;
- Prevent corruption: it is prohibited to offer or receive, directly or indirectly, money, gifts, or benefits of any kind for personal gain to or from directors, officers, or employees of clients, suppliers, public authorities, public institutions, or other organizations, for the purpose of obtaining an undue advantage or influencing the recipient’s independent judgment.
The following rules of conduct apply to the various categories of stakeholders:
Relations with Employees and Collaborators
Open Impact requires its employees and collaborators to be familiar with and comply with the provisions of the Code of Ethics.
Employees and collaborators are required to report any violations of the Code of Ethics committed by colleagues, collaborators, or consultants that come to their attention.
Open Impact may initiate disciplinary proceedings in response to reports made in bad faith with the intention of causing harm to colleagues and/or collaborators, as well as in cases where well-founded reports are intentionally withheld.
Collaborators and consultants who maintain relationships with Open Impact are required to avoid any situation that may give rise to a conflict of interest with the Company and, should such a conflict arise, they are obliged to report it to the Company immediately.
Open Impact requires its employees and collaborators to be familiar with and comply with the provisions of the Code of Ethics.
Employees and collaborators are required to report any violations of the Code of Ethics committed by colleagues, collaborators, or consultants that come to their attention.
Open Impact may initiate disciplinary proceedings in response to reports made in bad faith with the intention of causing harm to colleagues and/or collaborators, as well as in cases where well-founded reports are intentionally withheld.
Collaborators and consultants who maintain relationships with Open Impact are required to avoid any situation that may give rise to a conflict of interest with the Company and, should such a conflict arise, they are obliged to report it to the Company immediately.
Relations with Clients and Suppliers
Professionalism, expertise, transparency, and fairness are the guiding principles that all recipients of the Code must follow in their relationships with suppliers of services, works, materials, and professional services.
The procurement of services, works, materials, or professional services must be conducted with loyalty, confidentiality, diligence, professionalism, and impartiality by qualified personnel who take responsibility for their assessments and judgments, ensuring compliance with all applicable legal and regulatory requirements in the performance of their duties.
Employees involved in procurement processes must maintain the highest degree of independence in carrying out their responsibilities and remain free from any personal obligations toward suppliers. Any personal relationships between employees and suppliers must be disclosed to the Board of Directors before the start of any negotiations.
When establishing commercial relationships with new clients and/or suppliers, and in managing existing ones, it is prohibited—based on publicly available information and/or information obtained in compliance with applicable laws—to initiate or maintain relationships with entities that:
- Are involved in unlawful activities, particularly those related to the offences covered by Italian Legislative Decree No. 231/2001, or that otherwise lack the necessary standards of commercial integrity and reliability;
- Engage, even indirectly, in conduct that fails to respect human dignity and individual personality and/or violates fundamental human rights (such as child labor exploitation, facilitating migrant smuggling, or similar practices);
- Fail to comply with occupational health and safety regulations or, more generally, with any of the rules set out in this Code of Ethics.
It is also strictly prohibited to:
- Offer goods or services—particularly in the form of money or other benefits—to directors, general managers, executives responsible for preparing corporate accounting documents, statutory auditors, liquidators, or persons subject to the direction or supervision of any of the aforementioned individuals within third-party companies or organizations, in order to induce them to perform or omit acts in breach of their duties or obligations of loyalty, with the aim of obtaining confidential information or any direct or indirect benefit for themselves and/or for Open Impact;
- Accept goods or services from external parties where doing so would involve a breach of the duties associated with their role. Any information acquired in the course of relationships with suppliers must be kept strictly confidential.
Relations with Public Authorities
Relations with Public Authorities must be conducted with the utmost transparency and integrity. In particular, all necessary interactions shall be carried out in accordance with the roles and responsibilities assigned by law and in a spirit of full cooperation with government authorities and public administrations, both in Italy and in other countries.
It is prohibited to offer or accept gifts or favors of significant value in order to obtain preferential treatment in connection with any relationship with Public Authorities.
During any dealings with Public Authorities (including contacts, requests, negotiations, and similar interactions), Open Impact personnel—whether internal or external—must not attempt to improperly influence the decisions of the counterpart.
Open Impact may not be represented in its dealings with Public Authorities by third parties, consultants, or other representatives where a conflict of interest may arise. In all cases, Open Impact must exercise the utmost diligence to ensure that such third parties and their collaborators adhere to the same ethical principles and standards of conduct that apply to its own personnel.