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Pegaso International LTD - Ethical Code PEGASO INTERNATIONAL LTD - ETHICAL CODE PREMISE PAG. 2 1 MUTUAL RESPECT PAG. 2 2 TRAINING AND ADVANCEMENT OF CAREER PAG. 3 3 HEALTH, SAFETY AND ENVIRONMENT PAG. 3 4 USE OF BUSINESS RESOURCES PAG. 3 5 CONFLICTS OF INTEREST PAG. 4 6 CONFIDENTIAL INFORMATION AND RIGHT OF PRIVACY PAG. 5 7 DOCUMENTATION PAG. 5 8 FINANCING AND FUNDS PAG. 6 9 REPORTING PROBLEMS PAG. 6 10 SEXUAL HARASSMENT PAG. 7 11 GOOD BEHAVIOR PAG. 7 12 UPDATING OF THE CODE PAG. 8 ______________________________________________________________________________ Pag. 1 of 8 Pegaso International LTD - Ethical Code PEGASO INTERNATIONAL LTD - ETHICAL CODE _____________________ INTRODUCTION The Ethics Code is a "Constitutional Paper" of the rights and moral duties of the Pegaso International LTD, that defines the ethical-social liability of every person within the organization. The Code in which the addressees are required to observe the moral values and the principles described herein, is, in fact the main tool of implementation of the labor ethics which everyone must protect and preserve through their own behavior, the respectability and the image of the university, as well as its economic and human asset. BEHAVIOR IN THE WORK PLACE GENERAL GUIDELINES 1 - MUTUAL RESPECT All the winning organizations have an aspect in common: they have people who share a passion for their own job and work together towards a common objective. To create and to support a spirit of collaboration, every person who collaborates with Pegaso International should carry out his job to enhance the value of respect. - Offering support for the job activity; - Preserving an environment of positive work in which all have the possibility to learn and to grow professionally; - Never being involved in unlawful or violent behavior nor tolerating these acts; - Furnishing equal opportunities of employment to all the colleagues; - Developing impartial and constructive assessments of employment; - Fairly compensating the colleagues for the developed job; - Honoring the importance of people’s life outside the working environment. ______________________________________________________________________________ Pag. 2 of 8 Pegaso International LTD - Ethical Code Pegaso International believes in the absolute heterogeneous nature of the personnel and obviously - of its own users. For this reason, prejudicial or discriminatory attitudes are not tolerated towards: nationality, age, sex, sexual orientation, disabilities, political and religious beliefs. 2 - TRAINING AND ADVANCEMENT OF CAREER Pegaso International invests in resources which are necessary to allow everyone to properly express their potential skills, besides employing, motivating and keeping the best professional figures of the sector. The responsibility to ensure the appropriate level of educational training to everyone, is submitted to the managers and individual. Every manager must evaluate, and do everything possible to comply, with the demands for the training of the colleagues with the purpose to guarantee appropriate advancement of career. Similarly, each colleague must communicate to his own superior if he needs further training for his task. The managers must deal with all reasonable requests related to training, looking for the necessary resources for the educational training offer. 3 - HEALTH, SAFETY AND ENVIRONMENT Nothing shows the respect for others, more than the commitment shown by every collaborator of Pegaso International in order to guarantee that the work places and the procedures comply with health, safety and environment. It is important, therefore, to be always aware of the safety and health hazards and to assume in every moment a professional attitude and fully be in compliance with the standards health, regarding safety and the working environment. 4 - USE OF THE BUSINESS RESOURCES The necessary tools are submitted to every collaborator of Pegaso International in order to work as best as possible (telephones, photocopiers, printers, materials, computers, Internet access, boxes e-mail and computer software). These tools are property of Pegaso International and they must exclusively be used for working purposes. Nevertheless, the occasional and limited use of its resources is acceptable not for personal working purposes, provided that they are conform with the policies of the corporate body and the principles of the current Code and of good common sense. Those people who make personal and indiscriminate use of the tools of the corporate body can be submitted to disciplinary action and to their dismissal. ______________________________________________________________________________ Pag. 3 of 8 Pegaso International LTD - Ethical Code In case of any doubts, it is opportune to discuss these matters with his one’s own superior in order to establish if the personal use of these resources is appropriate. 5 - CONFLICTS OF INTEREST The respect of the legal ethical obligations to avoid conflicts of interest and to act with overall professional loyalty towards Pegaso International, is a fundamental presupposition for the growth of the same corporate body. This means that all must set the affairs of Pegaso International before any other professional or personal interest and never assume behaviors that could jeopardize the ethical and legal obligations, or the appropriate attitude required to carry out his own activities. Specifically, all the personnel such as executives, teachers or employees are forbidden to: - To take personal advantage of the opportunities that are included during the professional activity without previously getting the specific written approval of the Trustees; - To accept any participation to the Board of Administration of other corporate bodies or firms, as well as tasks in any other organization not connected with Pegaso International without previous approval written of the Trustees; - To participate in compromises on behalf of Pegaso International with other organizations in which they have a personal material interest, or with a family member (spouse, father, mother, sister, brother, child or daughter), without first having the specific written approval of the Trustees; - To participate in activities on behalf of Pegaso International that can negatively influence an independent and objective attitude, to be in contrast with the affairs of Pegaso or to jeopardize its own relationship of loyalty. To employ, to punish, to dismiss or to undertake any other claim related to the state of employment of a colleague with which there is a direct relationship (to es. spouse, father, mother, sister, brother, child or daughter); All those people to which this Code is directed have to previously communicate to their own superior or to the Trustees, all the participations or the activities that can determine a conflict of interest, for instance the affiliation to other corporate bodies, the tasks in other organizations or personal financial affairs. To collaborate with other institutions having the same purposes almost always represents a conflict of interest for a member of Pegaso International. ______________________________________________________________________________ Pag. 4 of 8 Pegaso International LTD - Ethical Code 6 - CONFIDENTIAL INFORMATION AND RIGHT OF PRIVACY Among the most precious resources of Pegaso International there is surely the confidential information from which the activities of the institution depend on. By way of example and not limited to such information includes: - Lists and information on the use; Personal documents of colleagues; Contracts, agreements and conventions; Business Plans; Marketing strategies, services or costs; Financial results before the publication; Information related to fusions, acquisitions, dismissal or planned negotiations. The destruction or the inappropriate spreading of confidential information can damage in meaningful way the affairs and the profits of Pegaso International. For this reason all those people who work for the institution must protect the property by undertaking all the necessary actions in order to safeguard its privacy. Similarly, it is important to respect the rights and the dignity of all the colleagues. Although it is fundamental to gather and store specific information, it is possible to acquire and to store only the necessary information according to law or related to carrying out the working activities. Pegaso International has established criterions and procedures, necessary to guarantee the conformity to all the current laws that discipline the spreading of confidential information. Only the personnel expressly authorized by the Trustees and exclusively for reasons can access and use such information. 7 - DOCUMENTATION Documentation represents an essential part of the activity of Pegaso International. For documentation, we mean e-mails, voice mails, computer files, financial records, written match, contracts and legal drafts. The whole documentation must be preserved in compliance with the provisions of the law related to the management of confidential deeds and to the various implemented procedures that establish standards by which documentation is managed during its lifetime - creation, use, filing and disposal. It is possible to contact the administrative Direction, in case of doubts related to the informative regarding management of documentation released by the university. ______________________________________________________________________________ Pag. 5 of 8 Pegaso International LTD - Ethical Code 8 – FINANCING AND GRANTS Pegaso International does not provide grants or financing, for any security, to political parties and movements and associations politically oriented. As well as for the individual candidates or grants devolved to supporting visible or hidden political and ideological corporations. 9 - REPORTING When a colleague intentionally or unintentionally does not adhere to the Code, to Pegaso International policies or to its fundamental values, everyone has the duty regarding such person, himself and whoever works for the institution to prevent, amend or signal such attitudes. In case of the existence of a visible or suspicious violation of this Code or of any other institutional policy, it is necessary to undertake one of the specific claims here described: a) To do one’s best in order to avoid the problem. If possible, to discuss the matter with the colleague in order to dissuade him to undertake claims that could violate the law or the rules of Pegaso International. b) To contact his superior. To examine immediately the matter with the superior. Almost all problems can and must be managed by him. If for any reason, it is necessary, communicate the situation to another responsible person. c) To address the specific office. To examine the matter with the responsible person of the specific office concerning that Area. In each office there are experts from different areas who can assist in problem solving. d) To address personnel office. An essential aspect of the mission of such office is to assist the colleagues in the matters related to the conditions of the job. Its task is to guarantee assistance in the cases in which unfair conditions subsist. e) To address legal office. In the legal office there are experienced professionals in the legal field. There is no legal request that cannot be satisfied by the legal office or by other experts with which it collaborates. ______________________________________________________________________________ Pag. 6 of 8 Pegaso International LTD - Ethical Code f) To address the security agency. The internal security agency is independent and endowed with surveillance powers and, therefore, in charge of the supervision of the adopted methods of management. Pegaso International, in fact, recognizes the importance of the implementation of an efficient and effective system of internal surveillance as an essential condition so as the carrying out of its own academic activities are in compliance with this Code. To such end, it guarantees to the organization the creation of the best conditions organizational and environmental – so that such functions are carried out independently by using specific resources related to the extension and difficulty of its tasks. The proper determination and assignment of tasks and responsibilities to those who act on behalf of this institution, constitutes a fundamental condition to the creation of an efficient, internal quality system, with a subsequent adaptation of a coherent architecture of operative proxies. In order to guarantee tertiarity, the surety agency consists of subjects not in conflict of interest with the administrative personnel and Pegaso International lecturers and if they are not connected with Pegaso International, they must not practice consultancy activities for this university. 10 - SEXUAL HARASSMENT Pegaso International is contrary to any type of sexual harassment and/or behavior that is immodest or not in good taste. All undesirable comments of sexual nature, unwanted physical contact and explicit or implied questions to offer or to receive sexual favors are all sexual harassment. They are considered sexual harassment the transmission and/or projection of explicit e-mail, and erotic or pornographic images on screens and screensavers of the computers of Pegaso International. 11 - GOOD BEHAVIOR There are finally some rules of good behavior that everybody, to put aside from his/her own role or organization, would be kept to observe, not so much for "professional duty", but rather because they refer to a context of civil cohabitation, responsibility and the creation of good interpersonal relationships. - if music is listened to, choose soft music and maintain a low volume; - even if smoking is forbidden, in cases in which a room is used for smoking, never forget to respect others; and not to take advantage of the possibility that is granted, to leave the workplace; ______________________________________________________________________________ Pag. 7 of 8 Pegaso International LTD - Ethical Code - besides smoking, other distractions from the job can be the recess coffee with colleagues, navigation on the web for personal motives or the habit of chatting with friends, acquaintances and relatives during office hours; - always knock before entering an office if the door is closed and to wait to be invited to enter before opening it. Before starting to speak ask if he is interrupting an important moment; - complaints and criticisms should be done in private and directly to the person responsible; - try to keep good relationships with everybody and to welcome with gentleness and consideration the new colleagues; - in case of difficulty, report them, try to maintain polite relationships however and not to adopt negative attitudes; - if talking to a superior of a problem risen in the office, introduce it as a professional problem and not personal. Talk of the problem calmly it and with diplomacy without blaming anybody, accept criticisms always appraising the positive aspect towards possible improvement; - beyond work roles, a series of small activities must be done by everybody, putting aside levels and work hierarchy and as everyone, shares the same working environment and its care, this also involves the responsibility and maturity of the people working there. 12 - UPDATING OF THE CODE The present Code can suffer changes or periodic integrations. Each new charge will be communicated to all the parties from the competent Office at the right moment. ______________________________________________________________________________ Pag. 8 of 8