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LEGAL AND ETHICAL CODE

LEGAL AND CONTRACTUAL CONDITIONS, PRIVACY & COOKIES AND ETHICAL CODE

 

LEGAL AND CONTRACTUAL CONDITIONS, CONDITIONS FOR THE EMPLOYMENT OF THE SERVICE, PRIVACY & COOKIES:

 

THE BOOKING OF A COURSE, THE PURCHASE OF A PRODUCT OR A SERVICE OR AN ADVICE, LIKEWISE THE PAYMENT AND/OR THE BOOKING OF THE COURSES OR THE EXPERIENCES, CONFIRMS THE VISION AND THE ACCEPTANCE OF THE BELOW CLAUSES AND CONTRACTUAL CONDITIONS.

 

1. Ferrari or other Supercars driving experience by Guida Sicura Supercar, tracks and/or equipped squares.

 

2. For technical or organization problems, even not serious, the dates of the events, the services, the course, etc… and the location could be altered until 5 days before their occurrence, even when previously confirmed. In case of events and training courses, the dates and the locations can be altered until 2 hours before their occurrence for reasons such as the inaccessibility of the tracks or the buildings/locations because of inclement weather, climate changes and other weather factors. Under no circumstance will be contemplated a refund but there will only be a change of dates or experience/event and/or course.

 

2.1. The experiences, the events and the courses (both purchased directly and through intermediaries and couponing systems) can be experienced only within 6 months from the purchase. Exceptions and/or postponements will not be contemplated under any circumstance. Bookings can be postponed or cancelled only once with no fine from the users/clients until 48 before the event/course/experience booked. Even in case of an annulment and/or postponement until the 48 hours before the date of the event/experience/course booked, the experience and/or course or the event must be booked in order to benefit of them within 6 months from the purchase. The date of the payment will be considered in the case. Under no circumstance will be contemplated refunds. Exceptions and/or postponements are not accepted, for any reason.

 

2.2. In case of purchase of a coupon through external dealer (Groupon, Smartbox, Glamoo, Letsbonus, etc..) the coupon must be forwarded by email to: francesca@guidasupercar.it and info@guidasicurasupercar.it at the latest within the 5 pm of the last day of booking/validity.Coupon forwarded over the 5 pm of the last day (namely the last daily working our in the office of GUIDA SICURA SUPERCAR SRL) will not be considered. It is compulsory, after sending the coupon, to call the secretary to the number 347 7913763 and/or to the contact numbers at the bottom of these contractual conditions to notify the sending, the confirm and the will to book since will not considered valid coupon sent by email not correctly delivered for any reason. Over the 5 pm of the last available day, the sent coupon will no more considered valid or usable. Under any circumstance is contemplated refunds. Exceptions and/or postponements are not accepted for any reason.

 

3. In the event of serious causes and/or acts of God not related to the will and/or the organization of GuidaSicuraSupercar.it (such as technical malfunctioning), what stated above subdues an exception. Every event/course/experience can be object of changes, postponements, delays and sudden annulments. The dates and the location of the events can be altered even during their own progress, even in the same day of the course without taking account of the 5 days or the 2 hours mentioned above.

 

4. The driver will be always and in any case responsible of his/her activity and of the damages by him/her provoked, both from a civil and penal point of view.

 

 

5. The Experience or the Courses will take place even in case of inclement weather conditions and beating rain, except for situations of technical impracticability of the tracks or of the locations with reference to the courses and the experiences on snow or ice.

 

6. The exposition photos of the website could not match the real experience or the employed car that will be anyhow a supercar. For driving on ice courses will be otherwise employed normal hatchback with snow tires.

 

 

7. It is not possible to choose the car. Following the arrival order, you will drive the car of your turn. ALL THE TESTS ACCOMPLISHED IN THE ICE AUTODROME (usually those of Sauze di Cesana, Pragelato and La Thuile) will be accomplished with normal car, not Ferrari 

 

8. Refunds are not contemplated in any case, we just provide change of dates and of experiences/courses.

 

9. Before driving and/or benefiting of the services, of the advice and of the trade of the products and/or the services, each user must sign a specific consent form, even with regards to the privacy. Once you drive a car for the experience of the course, you have explicitly agreed to every contractual clause and you have provided free and boundless consent to the use of the photos and videos of the driver alone or with other people during the event for every advertising or publication purpose.  Once you drive the car for the experience or the course, you explicitly authorize the public exhibition of photos and the images which portray you in public and/or to issue the above photos and images on websites, fan pages, blogs, social networks and/or to publish them and/or to make them published both on internet and in print for self-promotion or technical explanation purposes on whatever data carrier and position. This is in force also with regards to the attending to contests, exhibitions, events involving a participation of an audience or initiatives available on internet. Therefore, the above photos and videos could be used to promote the activities of GUIDA SICURA SUPERCAR SRL and so could be shown to clients or screened/posted up in their own offices and/or during events, fairs and show of whatever typology.

 

10. With reference to the tutoring training course, as much as for every other course/activity accomplished with our organization, we specify that we NEVER give any job guarantee. We do not offer a job but courses. Any working opportunity could rise with reference to the evolution of the market, the society itself and the maturity of the tutor, besides the Team Building reached with the already existing working group, but this involves only the exclusive and incontestable discretion of the Guida Sicura Supercar Srl Society, with no guarantees. 

 

11. For every controversy relating to the interpretation, the fulfilment, the validity and the efficacy of this contract, will be compulsorily made a conciliation attempt by a certificated institution of the Italian Ministry of Justice, in the area of the head office of the renter. The above process of mediation will be subdued to dispositions of the Decree Law no. 28/2010 and the subsequent alterations and integrations.

 

 

11. RIGHT TO WITHDRAW: despite the event can be postponed with a new booking until 48 hours before it, the right to withdraw can be asserted within a max. of 14 days (holidays included) from the payment disposition of the experience or of the course provided that this term is preceding the date of the first booking. Even in the event of a postponement of the course for natural causes, serious weather events, accidents, unavailability or malfunctioning of the cars or for other acts of God, the reference date to assert the right to withdraw remains that of the first booking. The right to withdraw must be asserted by a registered letter that must be sent to the head office: GUIDA SUPERCAR SRL P.zza G da Fabriano, 15 00196 Roma – the reference date will be the date of the effective receiving of the letter.

 

12. With reference to the above contractual conditions, we specify once again that a refund is not contemplated at all for any reason and under no circumstance as much as will not be accepted exceptions or postponements to the above contractual conditions for any reason and under no circumstance.

 

 

13. DISCLAIMER FOR THE SENDING OF EMAILS FROM ADDRESSES WITH DOMAIN @guidasicurasupercar.it

 

In conformity with the Italian Decree Law 196/2003, we specify that the information conveyed in this document are informal, not checked and not guaranteed, for an exclusive use of the receiver and reserved for him/her, not suitable to be exhibited in the event of legal controversies and protected by professional secrecy. The diffusion and the non-authorized use of them are strictly forbidden by anyone else but the receivers. In case you receive this message by mistake, we invite you to destroy it and to communicate us the wrong receiving by an email. 

 

 

 

Cookies Policy

Hereby, with this document, in conformity with articles 13 and 122 of the Italian Decree Law 196/2003 (“privacy code”) and of the Privacy Authority’s measure of the 8th may 2014, we inform the users about the cookies’ policy employed by the website guidasicurasupercar.com. This disclosure is accessible from every point of the website through the link at the bottom of the web page, in conformity with the art. 122 subparagraph of the Decree Law 196/2003 and in reference to the simplified conditions for the disclosure and the acquisition of the consent for the use of the cookies published on the Italian Official Gazette n. 126 of the 3rd June 2014 and the relating to the measures’ register n.229 of the 8th may 2014.

In compliance with the European legislation, it is crucial that every user of the website understand what the cookies are and why are they employed, so that the users can decide with consciousness whether to accept their employment on their own devices. A cookie is a little text file including a univocal identification number which is then transferred from the website to your computer’s hard disk by means of an anonymous code able to identity the computer but not the user ant to passively monitor your activities on the website. The cookies may be classified in two categories according to their own functions: Technical Cookies (including performance cookies and functional cookies) and Profile Cookies (including those cookies related to advertising). This website employs technical cookies which do not require any consent. There are also third-party cookies, deriving from advertising banners. More precisely, the website employs: performance cookies, which collect information about how the users use the website, like every pages are the most visited and whether the users receive error messages from these pages.                                                                             

These cookies do not collect information identifying a specific user. Every information collected by these cookies is anonymous and employed for the exclusive purpose of improving the performance of the website. Advertising cookies: these services allow to employ the Users’ Data for business communication purposes in various advertising forms, such as the banners, even in relation to the users’ interests. This does not mean obviously that all Personal Data are employed for this purposes. Data and employment conditions are as follows. Some of the following services could employ Cookie to identify the User or to employ the technique of the behavioral retargeting, namely to display personalized advertisings with reference to the interest and the behavior of the User, detected also beyond this Application. To know something more about this, we suggest you to check the privacy policies of the different services. Google AdSense: the website suggests advertising offers handled by the platform Google AdSense, so it is important to know that: - the third-party suppliers, such as Google, employ cookie to post ads relating to the previous visits of the user on the website. – the employment of the DoubleClick cookie allows Google and its partners to post ads for the users relating to their visits on your websites and/or other websites. – the cookies belonging to other suppliers or third-party commercial nets could be used for the posting of ads. The User can decide in every moment not to use the DoubleClick Cookie and so to disconnect it: google.com/settings/ads/onweb/optout?hl=it. Collected personal data: Cookies and employment Data. Place of the processing: USA – Privacy Policy. Hereby, this website, in conformity with the current regulation, is not required to ask a consent for technical cookies since they are necessary in order to supply the required services. For every other kind of cookie, the consent can be expressed by who is surfing the website through the following manners:

Through the configuration of the employed browser or of the other computer programs employed for the surfing.

Through the changing of the settings concerning the use of the services by third parties.

It is possible therefore, to visit the website even without accepting the storage of the cookies since it is enough to activate the option “do not accept cookie” in the browser. The most of the browsers accept automatically the cookies: changing this setting could cause a bad display of this and other websites.  Droniworld.com can include links to other websites following own privacy policies: droniworld.com is not liable for these sites.

Google Analytics

The website employs Google Analytics. It is a web analysis service supplied by Google Inc. (“Google”) which employs cookies that are then stored in the user’s computer in order to allow statistical analysis in aggregate form and in order with reference to the employment of the visited website. The data generated by Google Analytics are stored by Google as expressed by the following disclosure          https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. To consult the privacy policy of the company Google Inc., autonomous holder of the treatment of the Google Analytics related data, visit the website http://www.google.com/intl/en/analytics/privacyoverview.html. At the following link https://tools.google.com/dlpage/gaoptout?hl=it, moreover, Google provides an additional component of the browser for the deactivation of Google Analytics.

 

Social network’s buttons and widget

The social buttons are the “buttons” on the website which picture the icons of the social network (such as Facebook and Twitter) and that allow the surfing users to interact with a click directly with the social platforms. Below there are the links which can be clicked by the users to take vision of the privacy policy concerning the managing of data from the social buttons. https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter# https://www.facebook.com/help/cookies

 

Add This

The website employs Add This, which allows to add and manage the buttons of some social networks to allow the users to share the contents on the various social platforms.  The employment of this sharing service, involves the installation of the cookies, even profile cookies, of the third-party society which offers the service. The website however, does not share any surfing information or user’s data acquired in the event of the employment of these sharing button, except for some aggregated data. It is possible to take vision of the privacy policy concerning the Users who avail themselves of the AddThis Sharing Button at the following link: http://www.addthis.com/privacy/privacy-policy#publisher-visitors for the deactivation:      http://www.addthis.com/privacy/opt-out

 

Conditions of the treatment

The treatment is accomplished with automated tools of the Holder. Is not accomplished any divulgation or communication.

Conferring of data

Except for the technical cookies strictly necessary for the standard navigation, the conferring of data is handled by the concerned party who decided to surf the website after taking account of the brief disclosure included in the related banner and to benefit of the services which involve the installation of the cookie (same for the sharing of the contents through social buttons or through Add This).

The concerned party can therefore avoid the installation through proper functions available on his/her own browser explained below.

How to disable the cookie from the browser’s settings

Without prejudice to the above dispositions concerning the cookie which are strictly necessary for the surfing, the user can remove the other cookie by the proper function put at disposal by the Holder by means of the hereby disclosure or directly by means of the own browser. Each browser proposes different procedures for the managing of the settings. The user can get peculiar instructions through the below links. Microsoft Windows Explorer Google Chrome  Mozilla Firefox  Apple Safari – the deactivation of third-party cookies is moreover possible by the ways supplied directly from the third-party society holder of the treatment, as explained in the links reported at the paragraph “third-party cookies” – for further information about the cookies stored on your own terminal and to deactivate them one by one, go to the link:              http://www.youronlinechoices.com/it/le-tue-scelte - how to deactivate the cookies of third-party services.

 

Google Services

Facebook

Twitter

This page is available on the hereby website in conformity with the art. 122 second subparagraph of the Decree Law 196/2003 and in reference to the simplified conditions for the disclosure and the acquisition of the consent for the use of the cookies published on the Italian Official Gazette n. 126 of the 3rd June 2014 and the relating to the measures’ register n.229 of the 8th may 2014.

 

 

Cookie Remintrex Managing - Easy Touchpoint Integration

Extended Cookie Disclosure available at this link: //www.guidasicurasupercar.it/1/legali_codice_etico_3966346.html

Cookie Remintrex Managing: http://www.remintrex.com/site/?page_id=2528

 

Flagging the option of agreement for the data communication for marketing purpose, you agree to the employment of the web analytics service Remintrex. You agree to install the cookie which allows retargeting activity. In any moment, is it possible to cancell the cookie relating to this service, by a click on https://www.remintrex.com/ceng/pub/easy-unsubscribe.html?email=subscriber@example.com&lang=it">Cancellati

 

 

 

DATA PROTECTION POLICY

When the user signs up and accepts the conditions of the promotion, he/she automatically accepts his/her own data being part of GUIDA SICURA SUPERCAR SRL files. So, after the signing up, the user accepts the policy of privacy protection. Below we report the mentioned policies.

 

DISCLOSURE ABOUT PERSONAL DATA TREATMENT

(in conformity with the article 13 Decree Law 196/2003)

In conformity with the article 13 Italian Decree Law 196 of the 30th June 2003 (code about the protection of personal data), GUIDA SICURA SUPERCAR SRL informs you that the supplied personal data will be subdued to the treatment explained in the above mentioned disclosure, following the below standards:

1)     Purposes of the collection: the personal data supplied by you, will be processed and stored for the following purposes: accomplishment of the required activity, contests and operations with prizes; enrolment to users’ “communities” promoted on websites own or anyway connected to GUIDA SICURA SUPERCAR SRL; sending of information and advertising materials, sending of newsletter, other promotional and business communication operations, even by the employment of the email address, contractual and business partnerships, any other activity which the concerned party has joined taking account of the “ways to participate” mentioned above. In the event of contests organized by GUIDA SICURA SUPERCAR SRL, these contests involve the embodying of the data belonging to GUIDA SICURA SUPERCAR SRL’s Database. If the user does not approve his data to be included in this Database, he/she is invited not to enroll to the contests. Otherwise, provided the user does not communicate something different, his enrollment will imply the recording of his/her data in GUIDA SICURA SUPERCAR SRL Database and the explicit consent to the data treatment in order to receive advertising emails. If the user wants to withstand the inclusion of his data in the above mentioned Database, he/she must click on the proper section in the enrolment coupon.

 

2)     Conditions of the treatment and storage of the data. The data treatment will be accomplished with the tools and the conditions that will be considered suitable to protect the safety and the confidentiality of the personal data and might be accomplished both manually and both by electronic or automated means and it will involve all the operations contemplated by law and considered necessary to the treatment, including the communication to the entities mentioned in the following point.

In case of filled out coupon and information and services requirement, your data will be, in accordance with 196/2003 Decree Law, collected and processed for statistical studies and direct marketing activity, such as reception of commercial communication of third parties both by email and sms

 

 

3)     Some of the data might be processed through telematics nets, both with regard to local protected nets both with regard to the internet. With reference to the latter, the accomplished treatment will be subdued to the safety standards offered by the net. These data will be treated by operators of GUIDA SICURA SUPERCAR SRL and/or by operators of third societies entrusted by GUIDA SICURA SUPERCAR SRL, properly authorized to the treatment and the storage of the data and properly identified, directed and informed of the bonds imposed by the Italian Decree Law 196/2003.

 

4)     Kind of conferring: the conferring of personal data is optional but it might be necessary for the achievement of some of the purposes (managing of the contests and operations with prizes; activation of contractual and business partnerships, ecc.). The non-conferring of the compulsory data will not allow the payment.

 

5)     Communication of data: the personal data will not be communicated or divulgated to third parties, except for third-party societies that could be entrusted by GUIDA SUPERCAR SRL of the achievement of the purposes mentioned in point 1.

 

6)     Holder of the treatment: the holder of the personal data treatment is Francesco D’Alessandro c/o head office GUIDA SUPERCAR SRL in Rome, P.zza Gentile da Fabriano, 15 ZIP CODE 00196, legal pro tem representative.

 

7)     Rights of the concerned party: with reference to the personal data treatment, the concerned party has the faculty to assert the rights of the article 7 Italian Decree Law 196/2003, the text of whom is reported below. Art. 7 (right to access to the personal data and other rights)

 

The concerned party (by a mere email request at info@guidasicurasupercar.com) has the right to obtain the confirmation of the existence or of the non-existence of his/her own personal data, even whether not yet recorded, and their availability in an intelligible form.

 

The concerned party has the right to obtain information about: a. the source of the personal data; b. the aim and the conditions for the treatment of the data, c. the logic applied to the treatment accomplished by electronic means; d. the essential references of the holder, of the responsible people and of the representative person entrusted in conformity with article 5 subparagraph 2; the entities which could be involved in the data communication as representative entrusted in the area of the Country. The concerned party has also the right to obtain: the updating, the rectification and the integration of the data, b. the annulment, the anonymous transformation or the blocking of the treated data in case of a violation of the law, even for those data the storage of whom is not necessary with reference of the purposes for which they were collected; c. the certainty that the operations related to the letters a) and b) have been communicated to those who are aware of the personal data, except for the event of an impossibility in fulfilling this obligation.

 

The concerned party has the right to withstand, by an email communication at info@guidasicurasupercar.com, totally or just partly, for lawful reasons to the treatment of the personal data which involve him/her and are relevant for the purpose of their own collection; to the treatment of the personal data which involve him/her for the purpose of direct sale, sending of advertising material, market researches or business communication.

 

For further information concerning the conditions of the personal data treatment, the request of access, the changing or removing of the data, or to withstand their employment, please contact:

 

GUIDA SICURA SUPERCAR SRL head office Piazza Gentile da Fabriano, 15 00196 ROME

VAT NUMBER: 13250591008

Phone: +39. 347 7913763

Fax: +39 178.2240972

Email to: info@guidasicurasupercar.it

 

THE PAYMENT AND/OR THE BOOKING OF THE COURSES OR THE EXPERIENCES CONFIRMS THE READING AND ACCEPTANCE OF THE HEREBY CLAUSES AND CONTRACTUAL CONDITIONS.

 

Francesco D'Alessandro

CEO

@: info@guidasicurasupercar.it

M: +39 333. 300.800.6

P: +39 347. 7913763

F: +39 178.22.40.972

W: www.guidasicurasupercar.it

-----------------

Guida Sicura Supercar srl

Piazza Gentile da Fabriano, 15

00196 Rome

VAT NUMBER 13250591008

ETHICAL CODE *** ETHICAL CODE *** ETHICAL CODE *** ETHICAL CODE

ETHICAL CODE *** ETHICAL CODE *** ETHICAL CODE *** ETHICAL CODE - GUIDA SICURA SUPERCAR

ETHICAL CODE AND DISCIPLINARY SYSTEM

ORGANIZATION, MANAGING AND CONTROL MODEL

COMPANIES’ ADMINISTRATIVE RESPONSIBILITY (D.LGS. 231/2001)

 

In accordance to the CODE OF CONDUCT established by the 231 ANAV Decree Law 8th June 2001

approved the 3rd of July by the Ministry of Justice

 

the Ethical Code adopted by GUIDA SICURA SUPERCAR SRL is a whole of principles and norms which is strictly important to follow in order to contribute to the good proceeding and the improving of the company’s liability. It represents the “Charter of fundamental rights and duties” employed by the Company to:

  • Specify its own ethical and social responsibilities with regard to various concerned parties both internal and external, like: shareholders, employees, partners, suppliers, public bodies, clients, etc.;
  • Research of balancing forms and/or equilibrium points between the manifold interests and the proper expectations of the stakeholders.

The adoption of this Code aims primarily to satisfy in the best way the needs and the expectations of the company’s stakeholders, by promoting and fostering a high level of professionalism and forbidding those behaviors that contrast with the concerned current norms and with the values the Company wants to promote. The individual and general conduct of the employees and partners of the Company must therefore be in accordance with the company’s policy and must involve collaboration, social responsibility and observation of the current rules following the conduct’s principles established by the Ethical Code.

The adoption of this Code integrates and enrich the norms of the Company’s Regulation in the context of:

  • Conduct Code of the Company’s Staff;
  • Manual of the Driving Staff;
  • Company’s Regulation for the employment of the computer system;
  • Procedures of the Quality Management System.

 

RECIPIENTS

The Ethical Code involves everyone, partner or employee, that establish with the Company a kind of relation, direct or indirect, temporary or permanent, or that collaborate to pursue the company’s goals. These parties will be hereafter called “recipients”. The recipients who violate the principles and the norms established by this Code, damage the trust relation build with the Company. All the recipients are required to know the Ethical Code, to contribute to its accomplishment, its improving and its promotion. The Company commits itself to provide every employee and partner a copy of this Code and to promote its contents and aims.

 

GENERALE ETHICAL PRINCIPLES AND MISSION OF THE COMPANY

The principles on which the Company’s Ethical Code is founded are the following:

  • Ethically correct and accordant with the norms Conduct of the Company and of its manifold stakeholders;
  • Loyalty of partner and employees towards the Company;
  • Honesty, politeness and respect in the relationships among colleagues;
  • Professionalism and diligence;
  • Respect of the environment and of the health and the safety of partners and employees.

The Company commits itself to observe concretely the values and the principles established by the Code, by taking responsibilities on itself towards the inside and the outside and by strengthening trust and cohesion. Thus, it commits itself to set up an action of formation and information about the contents of the Code with the below purposes:

  • To foster and strengthen the values on which the company’s policy is founded;
  • To spread the norms and the procedures that must be respected;
  • To extend the approval of the basic principles of the Code.

 

The ethical conduct standards that the Company aims to pursue are the following:

  • Fairness and equality in the relation with the human resources of the Company;
  • Diligence, honesty, discretion and fairness in the carrying out of the company’s activities;
  • Safeguard of people and environment.

 

The mission of the Company is to promote the fundamental principles of the Safe Driving, to inform and form hoping to contribute to a decrease of the traffic accidents and the consequences of them and to pursue the business goals by the carrying out of the services of rental.

The network of the offered services has been organized in order to guarantee to the people the best accessibility possible from study and work locations in a context of integration and specialization of the manifold transport ways.

The Company has furthermore improved the business activities by pursuing the aim of the UNI EN ISO 9001 Certificate of Quality, which is particularly focused on the organizational and managing context of the Company with a careful attention to the inner resources and the shareholder of the Company, such as Clients and Suppliers.

 

CONDUCT’S NORMS AND STANDARDS

GUIDELINES FOR THE RECIPIENTS’ POLICY

GUIDA SICURA SUPERCAR commits itself to:

 

  • Guarantee equal job opportunities to every employee or partner with reference to their professional qualifications and their skills, without any discrimination based on race, religion, opinions, nationality, gender, age, physical and social conditions;
  • Guarantee to every employer or partner a working places and job relations without sexual harassment, threatening and hostile behaviors or actions to the prejudice of individuals or group of employees which could negatively interfere with the carrying out of the working activity or with the job expectations for mere reasons of competitions;
  • Improve the skills and the competences of each employee or partner with activities of formations and updating;
  • Guarantee an equal treatment based on criteria of competence and merit;
  • Protect the information acquired or generated in the inside or the outside of the Company concerning employees and partners and take very precaution to avoid an improper use of the information itself;
  • Foster and protect the health and the safety of employees and partners.

 

The Company also commits itself to considerate with particular attention the condition of those who feel uneasy in a smoking environment and to discourage anyway smoking in the working place, except for designated areas.

 

The recipients commit themselves to: 

  • Respect the contract with reference to the tasks, the goals and the responsibilities assigned, without delegating to other employees or partner the carrying out of activities or the decision-making burdens;
  • Respect the working hours, whether employees, unless they have valid reasons to do that and to limit the absence from the working place to those which are strictly necessary;
  • To dedicate the proper effort, whether partners, in terms of time and devotion to the assigned tasks in order to pursue the relative goals;
  • To adopt a respectful and sensible behavior towards the other people, avoiding to work under the effect of alcohol, narcotics or other substances with similar effect and to have or give to someone else these substances during the working activity;
  • To contribute to the creation of a positive professional environment in which every other employee or partner can feel comfortable in the pursuing of the company’s tasks;
  • To correctly employ the resources and the properties provided by the company with reference to the use they are intended to in order to safeguard their proper functioning, since every recipients is considered directly and personally responsible for the safeguard and the preservation of the resources and the properties he/she has been provided. Therefore, they commit themselves not to employ the company’s telephone lines for personal reasons, unless an emergency situation requires to and they also commit themselves to observe the directions given by the Company’s Regulation about the use of the computer system for the employment of internet and emails. They also commit themselves not to employ the company’s vehicles for personal reasons and not to transport external people, unless the Company requires to;
  • Take the highest care and caution in the employment of information achieved during the working activity which is not common knowledge. Both the information and every other material achieved within the carrying out of the job are property of the Company. The recipients commit themselves not to spread, use or communicate either information nor every other kind of news, documents, data, etc, relative to the working activity without a specific authorization;
  • Avoid every situation or activity which could involve a conflict of interest in the activities carried out for the company or could damage the interest of the company itself. In case of occasional occurrence of a situation of real or potential conflict of interest, it is required the highest communication and honesty of the problem to the concerned person;
  • Accept or offer, directly or indirectly, politeness and courtesy acts in the commercial context, such as gifts, payments and benefits only if their acceptance or offering is aimed to the acquiring of advantages for the Company. If an employee or a partner accepts/offers gifts which cannot be considered as a normal polite action, he/she must immediately inform the concerned people and refuse;
  • Partake to the process of prevention of risks, safeguard of the environment and of the health with regard to the recipient himself, colleagues or third parties.

 

ADMINISTRATIVE RESPONSIBILITY

Objects of particular importance are the fairness, the accuracy and the completeness of the Budget. With reference to this, each employee is required to cooperate in order to correctly portray the managing matters. Each report must be in accordance with the principles of honesty, fairness, completeness and accuracy. The accounting records must be based on precise, exhaustive and verifiable. Each record of the accounting books must reflect the kind of the operation, depict its essence and must be based on a proper support documentation, in order to:

  • Facilitate the accounting record
  • Allow the identification of the different responsibilities
  • Allow a precise impression of the operation

If an employee or a partner becomes aware of facts like forgeries in the accounting or in the documentation on which the accounting is based, he/she must immediately communicate the news to the people in charge, who could involve the supervisory body (Organismo di Vigilanza e Controllo).  If the forgeries or the lacks involve the people in charge, the employee or partner must inform directly the supervisory body. If the report turns to be absolutely groundless, the Company can start a disciplinary action against the employee or interrupt the professional relation with the partner.

 

GUIDELINES IN THE POLICY TOWARDS THIRD PARTIES

Employees and partners must properly inform third parties about the contents of the Ethical Code, in order to conform the conduct of the third parties themselves to the above directives.

 

RELATIONS WITH CLIENTS AND SUPPLIERS

Each recipient must accomplish its tasks with the purpose to get the greatest satisfaction of the Client. Whether asked, every recipient is required to provide information and assistance in a polite, correct and exhaustive way.

The choice of the suppliers and the determination of the purchase conditions must be based on an objective evaluation of:

  • Quality of the required products and services;
  • Price of the required products and services;
  • Ability of the supplier to promptly provide and guarantee products and services of a proper quality in relation to the needs of the Company.

 

RELATION WITH THE PUBLIC ADMINISTRATION

Every kind of relation or commitment with the Public Administration is reserved only the concerned company’s bodies. The recipients must not promise, offer or accept payments or products from government officials to promote or facilitate the interest of the Company, unless it deals with a mere act of commercial politeness with a moderate value that cannot be interpreted as aimed to acquire advantages for the person or the Company in an improper way. In case of offers/proposals from government officials, the partner or employee must immediately inform the concerned people and refuse. In case of relations (contacts, requires, negotiations, etc.) with the Public Administration, the staff entrusted by the Company (internal or external) is not allowed to try to influence in an improper way the decision of the counterpart. In the context of competitions with the Public Administration, the concerned figures must operate in compliance with the norms and the correct commercial practice with respect for the competitions’ rules. The Company commits itself to adopt and make its employees and partners adopt a correct conduct with reference to the Public Treasury.

In the context of the relations with the Public Administration, the Company cannot be represented by third parties (consultants, etc.) in the event of conflicts of interests. The Company commits itself to spread the contents and the purposes of the Ethical Code among every recipient (internal or external), so that they can apply the ethical directives. During each kind of relation with the Public Administrations, such as contacts, requires, negotiations, etc., it is not allowed to carry out, directly or indirectly, the below actions:

  • Examine or propose job/commercial opportunities which can bring benefits to the Public Administration;
  • Demand or get confidential information which can prejudice the reputation or the integrity of one or both the parties;
  • Offer or provide gift/benefits.

 

RELATIONS WITH POLITICAL ASSOCIATIONS, MASS-MEDIA AND TRADE UNIONS

Guida Sicura Supercar Srl does not provide direct or indirect contributions either to parties, movements, committees, trade unions and political associations and nor to any of their agents or candidates. The relations with press are carried out by authorized figures and in compliance with the company’s policy.  The provided information must be truthful, complete, accurate, honest and homogeneous with each other. Partners and employees are not allowed to issue any interview or declaration involving the Company without an authorization of the concerned people to members of the press or another media.  

 

CONTROLS

The inner control system consists of a group of means employed to manage and check the business activity, direct it towards the assigned goals and oppose the risks. The control system must provide a warranty about the respect of the State laws, such as of the inner procedures, the Company’s codes, the achievement of the prefixed goals, the safeguard of properties and resources of the Company, the managing of the company following criteria of efficacy and efficiency and the reliability of the accounting information towards both the inside and the outside of the company.                                                                               

The Company commits itself to define a procedures’ system aimed to reduce the risk of Code’s violation by assigning responsibilities and resources to an inner vigilance and control body, the task of whom is to elaborate proper guidelines with reference to the manifold company’s figures.

 

 

VIOLATIONS OF THE ETHICAL CODE

The rules of the Ethical Code integrate the conduct the employee is required to respect, based on the current norms regulating collective bargaining.

Violating the Code damages the trust relation created with the Company and whether the infringement is considered a non-fulfilment of the contract (both for an employee and a partner), in accordance with Art. 2104 of the Italian Civil Code, the Company can begin disciplinary or legal actions. In the most serious cases, the violation could bring to the termination of the professional relation, both for an employee and for a partner or a third party, such as a supplier.

 

 

DISCIPLINARY MEASURES TOWARDS MAYORS AND ADMINISTRATORS

In case of violation of the norms or adoption of behaviors/acts in contrast with the directive or the principles of the Italian company’s organization, managing and control model, also known as MOG, by administrators and/or mayors, the vigilance and control body must inform the board of directors and that of the auditors, who will take the proper measures, such as calling a meeting for the partners and propose alternative measures in accordance with the Law.

Without prejudice to the actions provided by the Corporate Law against administrators, the disciplinary measures can consist of formal reprimands and suspension of the office if authorized by the board of directors, with reference to the kind of infringement.

 

 

MEASURES TOWARDS EXTERNAL SUBJECTS

In accordance with the organization, managing and control model, every activity and behavior of the external subjects in partnership with the company (such as consultants, partners and so on) which turns to be in contrast with the guidelines and the conduct’s norms of the model or which touches the sphere of the administrative responsibility, will be subjected to the consequences taken into account by the contract in terms of sanctions and termination of the negotiating bonds. For this purposes, the contracts are integrated with specific clauses aimed at warrantying the respect of the conduct’s principles of the model.

 

 

MEASURES TOWARDS MANAGERS

 

In the case of violation of the model and its principles by a manager or in case a manager allows a cooperator to adopt behaviors not suitable with the model and its principles, the most proper measures will be applied in accordance with the current contractual and legal norm.

 

MEASURES TOWARDS EMPLOYEES

The sanctions are those taken into account by the “Titolo IV del Regolamento Allegato A al Regio Decreto 148/1931”

 

IMPLEMENTATION MEANS

The responsibility for the appliance of the Ethical Code is entrusted to the Board of Directors operating through an internal body of the board itself, named “Vigilance and Control Body”. The Board appoints the Body, the member of which are in charge for three years with the faculty of being appointed again. The requirement for the members of the Body are:

  • Autonomy and independence. The members do not carry out operative activities since this kind of involving could affect their objectivity and their judgement or could bring to economical/financial decisions;
  • Professionalism. Each member must have the necessary competences in order to carry out with efficacy the assigned tasks both from a technical point of view, both as consultants;
  • Continuity. The Body must dedicate the needful time to the accomplishment of the assigned tasks.

 

The tasks of the Body are the following:

  • Warrant the widest possible spread of the Ethical Code among all the recipients;
  • Inform the Board of Director at least once a year about the implementation of the Code;
  • Supervise the coherence between the principles of the Ethical Code and their appliance among employees and partners and therefore analyze every fact with recipients and concerned figures;
  • Check the efficacy of the Code in the contrast with the unaccepted behaviors and conduct;
  • Update the Code to keep it suitable to the Company’s life.

 

Guida Sicura Supercar Srl

 

 

 

 

GUIDA SICURA SUPERCAR

GUIDA SICURA SUPERCAR