Ethical code

Premise

In order to promote the quality of the activity carried out by Hubrains for innovation and the dissemination of a spirit that contemplates adequate behavioral standards in compliance with current legislation and the system of values to which it refers Hubrains, it is considered necessary to establish a specific Code of Ethics, which expresses the guidelines and the style of behavior to adopt and identify with.

This code must be the expression of all members of Hubrains details in point 1 - so that, in their work, they adopt the principles in which Hubrains i recognize and inspire it.

The Code of Ethics is therefore an institutional document that intends to ethically regulate the internal relations of the company between the constituent bodies, shareholders, employees, collaborators as well as external relations that Hubrains entertains with his own stakeholders of whatever nature they are.

The Code of Ethics represents, in fact, a regulatory instrument capable of stably regulating the behavior of individuals and shareholders towards the set of ethical-disciplinary values constituting the purposes of HubrainsMembership and / or collaboration with Hubrains implies, in addition to compliance with the general legal regulations in force, the acceptance of this Code of Ethics.

The Code of Ethics is an effective means of preventing irresponsible or illegal behavior by those who work in the name and on behalf of Hubrains. The Code of Ethics introduces a clear and explicit definition of ethical and social responsibilities towards all subjects directly or indirectly involved in the activity of Hubrains(customers, suppliers, citizens, employees, collaborators, public institutions, associations and anyone else interested in the activity of Hubrains.

In this sense, therefore, the Code of Ethics constitutes one of the prerequisites of the organization, management and control model adopted by Hubrains .

The Chairman, the Board of Directors, the management, the employees of Hubrains, all profit and non-profit organizations and people directly and indirectly involved in the activities of Hubrains they undertake to enforce the behavioral principles referred to in this Code of Ethics and by the reference standards in force. These principles, translated through the procedures and actions of the entity, must be respected by all recipients: each is required to read this code and operate in compliance with the reference value system expressed in it, so that Hubrains develops within the ethical criteria, as identified in the Statute and in the Code itself.

1. Recipients and scope of application

The Code of Ethics applies to HubrainsThe principles and provisions expressed therein are binding for the directors and for all those holding corporate offices, for the shareholders, for the management, for the employees and collaborators and for all those who work for Hubrainswhatever the relationship, even temporary, that binds them to the company (eg interns, trainees, volunteers).

They, hereinafter jointly referred to as "Recipients", are required, without distinction or exception, to observe and enforce the principles identified below, to protect and preserve, through their conduct, the respectability and image of Hubrains, as well as the integrity of its assets, understood as both physical and intangible assets and resources.

In the face of this, Hubrainspromotes the widest dissemination of the Code of Ethics among all interested parties, the correct interpretation of its contents and provides the most appropriate tools to facilitate its application.

The Code of Ethics is also brought to the attention, in the forms and ways deemed most suitable, of all third parties who receive assignments from Hubrains (consultants, teachers, planners, etc.) or who have stable or temporary relationships with it.

The Code of Ethics does not replace and does not prevail over the existing laws in force on the subject of work.

2. The structure of the Code of Ethics

This Code of Ethics consists of:

  • Ethical principles that define the reference values of Hubrains in carrying out its activities and which must inspire the behavior of the recipients;

  • Criteria of conduct towards each class of stakeholders that –Hubrains and its Collaborators are required to follow in order to respect the ethical principles adopted and to prevent the risk of unlawful conduct;

  • Implementation methods, which describe the control system aimed at verifying compliance with the Code of Ethics and its improvement.

3. Hubrains mission, vision and values

3.1 Mission

Hubrains wants to share innovation, knowledge and creativity to face the challenges of tomorrow today, through social innovation and cultural growth, with attention to the quality of life of people and the environment, where social relations are essential to achieve these goals.

Hubrains it also responds to customer needs quickly, guaranteeing a high quality service and technology. The deep knowledge of the global market and the continuous research and development in innovative technologies and systemic thinking ensure an optimal result.

3.2 Vision

Hubrains - take a step forward: social innovation, cultural growth and new technologies are the key challenge for the new generations and businesses in the near future
Hubrains- We want to contribute to the creation and development of a new economic scenario based on ethical values and with a high social impact, dedicating ourselves to business projects and undertaken through an integrated ecosystem oriented to the development of young people with high potential and innovative companies.

3.3 Values

The values to which the whole organization is oriented are:

  • centrality and respect for people and the environment

  • the respect and trust of all people and organizations involved with Hubrains

  • guarantee the present and a better future through social innovation and cultural growth.

  • the organization, as well to ensure the best performance towards internal customers, external customers and suppliers

  • innovation at all levels, to support the continuous changes underway in the technological world,

  • the search for the highest possible efficiency, ensuring consistent financial sustainability;

  • quality as a certified attestation of the activity and intrinsic value;

  • the close link between design activities and their implementation;

  • the high continuing education of all persons directly or indirectly involved with HUBRAINS

HUBRAINS it also intends to strengthen its role of reference of the professional areas already identified in the mission in close connection with all the advanced realities and carriers of innovation of national and international interest in a real one vision modern and integrated.

In conducting its business, HUBRAINS it is independent of any conditioning of a political nature.

4. Ethical principles of reference

HUBRAINS Yes it inspires in its activity to the ethical principles listed below, the true foundation for every behavior and for every moment of the life of the organization.

Legality: HUBRAINS undertakes to comply with all national and international standards, laws, directives and regulations. It also inspires its decisions and behaviors to the care of the interest entrusted to it.

Honesty: honesty is the fundamental principle for all activities of HUBRAINS and constitutes the essential value of internal organizational management among collaborators and externally. Relations with stakeholders and collaborators are based on criteria and behaviors of correctness, collaboration, loyalty and mutual respect.

Responsibility towards the community and environmental protection: HUBRAINS, aware of its social role, it undertakes to operate in compliance with local, national and international communities, developing initiatives that know how to combine the interest of individuals and the community, with a view to contributing to the improvement of the quality of life in the territories in which it is active, with a view to social innovation, cultural growth and environmental sustainability.

Transparency: HUBRAINS undertakes to operate in a clear and transparent manner, without favoring any interest group or single individual. HUBRAINS pursues transparency within the organization between shareholders, collaborators and towards the recipients of its services: employees and collaborators of HUBRAINS are required to provide complete, transparent, understandable and accurate information to users / customers, so that they are aware of the characteristics and purposes of the services and products offered by HUBRAINS.

Enhancement of human resources: HUBRAINS recognizes the centrality of human resources and believes that the professional contribution of the people who work there is an essential factor for the success and development of the organization. Human resource management of HUBRAINS it is based on respect for the personality and professionalism of each of them, in a framework of loyalty and trust and equal opportunities. All employees and collaborators are called to contribute to the promotion and maintenance of a climate of mutual respect with particular regard to the sensitivity of others.

Efficiency and Quality of services and projects: HUBRAINS undertakes to offer a service tailored to the needs of the user / customer in line with the highest standards. Furthermore, every activity and project must be carried out according to the principle of economic management of the resources used.

Attention to the customer: HUBRAINS directs its business to customer satisfaction by paying attention to requests that can favor an improvement in the quality of products and services and by monitoring all processes. The behavior style of HUBRAINS towards users it is based on availability, respect and courtesy, with a view to a collaborative and highly professional relationship. In particular, in communicating with users HUBRAINS ensures completeness, correctness and clarity of all information on the service offered.

Confidentiality: HUBRAINS ensures the confidentiality of the information in its possession and refrains from seeking confidential data, except in the case of express and informed authorization and compliance with the legal regulations in force. In addition, the collaborators of HUBRAINS are required not to use confidential information for purposes not connected with the exercise of their business.

Protection of health and safety in the workplace: as part of its business HUBRAINS pursues the objective of protecting the safety and health of its resources, adopting all the measures envisaged for this purpose by the law.

5. Rules of conduct

5.1. Relations with collaborators

HUBRAINS recognizes the value of human resources (employees, collaborators and those who carry out a professional service on behalf of HUBRAINS also free of charge, hereinafter generically referred to as "collaborators") and the importance of their contribution to the activity of HUBRAINS and therefore promotes their professional growth and the constant acquisition of skills.

Personnel selection is carried out on the basis of correspondence between the candidates' profiles and the needs of HUBRAINS in compliance with the principles of impartiality and equal opportunities for all candidates, avoiding any form of favoritism, patronage or nepotism.

HUBRAINS is attentive to equal opportunities in the workplace and adopts policies and tools in favor of reconciling family and work life.

HUBRAINS it also undertakes to protect the moral and physical health of its collaborators in compliance with current legislation on prevention and protection, using all measures to ensure a safe and healthy working environment.

HUBRAINS protects the privacy of its employees and collaborators, according to the regulations in force on the subject, undertaking not to communicate or disseminate, without prejudice to legal obligations, the related personal data without the prior consent of the interested party and has adopted specific procedures aimed at guaranteeing the protection of such information at all stages of their processing.

5.2. Enhancement of diversity (Diversity Management)

In managing its resources, HUBRAINS rejects any discrimination based on age, ethnicity, gender, nationality, religion, language, family situation, disability, reference social group or policy at all stages of the employment relationship between the Management and the "collaborators ".

HUBRAINS it also promotes a process of inclusion and development of the diversity of its “collaborators” and puts people, each with their own needs and peculiarities, in a position to achieve their goals consistently and compatibly with those of the company.

The enhancement of diversity is reflected in the same way in the behavior towards stakeholders external: from customers, to suppliers, to the wider community.

5.3. Duties of directors and of those who hold corporate offices

The directors and those who hold corporate offices in HUBRAINS are required to comply with current legislation and the principles contained in this Code of Ethics, as well as the Articles of Association and the regulation of HUBRAINS.

Their behavior must be inspired by principles of correctness and integrity, also in order to protect the assets and image of HUBRAINS.

They must guarantee assiduous and informed participation in the activity of HUBRAINS.

As part of their activity in HUBRAINS the collaborators cannot use their position to obtain personal advantages, direct or indirect, and must avoid situations of conflict of interest.

In carrying out the mandate and following the termination of the relationship with HUBRAINS have the obligation of confidentiality on the information concerning HUBRAINS and its activities.

5.4. Duties of collaborators

All collaborators undertake to comply with the obligations set out in this Code and to comply, in carrying out their duties, with full compliance with the law, basing their conduct on principles of integrity and correctness.

They undertake to act loyally in compliance with the obligations set out in the employment contract, respecting the commitments undertaken, the work of other collaborators and acting in such a way as not to risk damaging or compromising the reputation and image of HUBRAINS.

Collaborators must avoid relationships that may lead to conflicts of interest with their organizational role and undertake to communicate in advance to the Supervisory Body any situation of conflict of interest, real or potential, according to the established methods.

They must also pay particular attention to the relationship with other collaborators, inspired by the principles of correctness, transparency, respect, courtesy, availability and responsibility, in order to create and maintain a positive work environment, oriented to the results and objectives of the 'organization. They therefore undertake to avoid actions and decisions that can have burdensome consequences on the organization both in terms of relationships and work.

Employees are required to keep information on HUBRAINS, on its customers and on the internal resources that work there, learned in the performance of work activities, in accordance with the law, regulations and circumstances and to carefully guard the documents, data and tools entrusted to them. This obligation must be maintained even after the termination of the employment relationship.

All collaborators (employees and consultants) must promptly report to the Supervisory Body (jointly informing their Manager) any news they become aware of in the exercise of their functions, regarding violations of legal regulations, the Code of Ethics or other provisions that may, in any capacity, involve HUBRAINS.

Finally, collaborators are required to scrupulously comply with the regulations on health and safety in the workplace and the internal procedures adopted by HUBRAINS in this context.

5.5. Relations with customers / users

HUBRAINS establishes a relationship with its users / customers characterized by high professionalism, availability and collaboration, transparency and fairness, committing itself to respect the commitments made.

Communications to customers / users and agreements entered into with them must be formulated in a clear, simple and complete manner, in compliance with current regulations, without resorting to elusive or otherwise incorrect practices.

HUBRAINS protects the privacy of its users / customers, according to the regulations in force on the subject, undertaking not to communicate or disseminate the related personal data, without prejudice to legal obligations, adopting the most appropriate tools to guarantee their protection during the processing of themselves.

5.6. Relations with suppliers and consultants

The selection of suppliers and consultants must be authorized by HUBRAINS, in compliance with the regulations in force and with the internal procedures envisaged. The choice must be based on the objective assessment of the quality, price, ability to promptly supply and guarantee goods and services of an adequate level for the needs, as well as on the integrity and solidity of the individual identified.

Collaborators are required to HUBRAINS to ensure equal opportunities, during the selection phase, to supplier companies and consultants who meet the required requirements. Any derogation from the principle of free competition must be authorized and justified.

HUBRAINS prohibits the recognition of fees that are not justified in relation to the type of good / service acquired and to market prices.

The relationship with suppliers and consultants must be based on fairness, professionalism, efficiency, seriousness and collaboration.

To the collaborators of HUBRAINS it is forbidden to directly or indirectly receive money and personal favors from suppliers and consultants aimed at obtaining undue advantages. They can accept gifts of only symbolic value, promptly informing their line manager and / or the directors of HUBRAINS and this also applies to the directors of HUBRAINS. Gifts and other forms of courtesy are allowed to suppliers and consultants, provided they are of modest value and such as not to compromise the integrity and reputation and with prior authorization of the expense.

Similarly, the collaborator cannot accept remuneration, gifts or preferential treatment of more than symbolic value and is obliged to inform his / her supervisor and / or the directors of HUBRAINS of the offers received to that effect.

HUBRAINS undertakes to inform the supplier / consultant with precision and timeliness about the characteristics of the activity, the forms and payment times. For its part, the fulfillment of contractual services by the supplier / consultant must comply with the principles of correctness, honesty and commitment and must take place in compliance with current legislation.

5.7. Relations with the Public Administration

HUBRAINS maintains relations and relationships with state administrations, guarantors and supervisory authorities, public bodies, local administrations, public law organizations.

Relations with the Public Administration must be initiated and managed in full and rigorous compliance with the laws and regulations in force and based on clarity, transparency, collaboration, professionalism and the recognition of their respective roles.

In relations with public officials, directors, employees and collaborators must behave in accordance with the utmost fairness and integrity, also avoiding giving the impression of wanting to improperly influence decisions or requesting preferential treatment.

About this, HUBRAINS puts in place the appropriate precautions and suitable measures to prevent similar behavior by those who act in their name and on their behalf and which could be configured as corruption of a public official or a person in charge of a public service.

It is forbidden to offer / receive directly or indirectly money, gifts, or benefits of any kind in a personal capacity to / from managers, officers or employees of customers, suppliers, Public Administration entities, Public Institutions or other Organizations for the purpose of obtaining undue advantages and to influence the recipient's independent judgment.

Acts of courtesy, such as gifts and forms of hospitality to representatives of the Public Administration or public officials are permitted, as long as they are of modest value and such as not to compromise the integrity and reputation and do not affect the recipient's independent judgment. In any case, such expenses must always be authorized and adequately documented.

Similarly, the collaborator cannot accept remuneration, gifts or favorable treatment of more than symbolic value and is obliged to inform his hierarchical manager of the offers received in this regard.

In relations with the Public Administration, the Recipients must make the data and documents available in a timely manner and in compliance with any deadlines and in clear, objective and exhaustive language in order to provide accurate, complete, faithful and truthful information.

HUBRAINS prohibits submitting incomplete, false or altered data and documents to the Public Administration.

5.7.1. Management of public and private funding and contributions

HUBRAINS, when requesting and managing grants and loans of any nature obtained from the State, from other public or private entities, observes compliance with the principles of legality, transparency and fairness.

To this end, the recipients of this Code of Ethics must:

  • represent the interests and positions of HUBRAINS in a transparent and rigorous manner;

  • carry out a scrupulous check of the data contained in the declarations addressed to the supplying bodies.

The collaborators in charge of preparing the documentation necessary for participation in public tenders / notices or for the presentation of grant applications, must:

  • transmit truthful information;

  • ensure the completeness and updating of such information;

  • comply, in the transmission of the documentation, with the deadlines set by the public administration concerned.

The assumption of commitments with Public Administrations and Public Institutions is reserved exclusively to the designated and authorized functions, who will carry out their duties in due respect of the laws and principles of this Code of Ethics and in full compliance with the protocols provided for by the Organizational Model of HUBRAINS.

Anyhow HUBRAINS and its employees, collaborators and directors undertake to report to the Supervisory Body any information of conduct contrary to the principles set out above which they come to knowledge, even if held by any partners.

6. System of sanctions

HUBRAINS implements the necessary measures in order to carry out verification and monitoring of the application of the Code of Ethics.

Violation of the provisions contained therein and in the Organizational Model of HUBRAINS (as well as in the company procedures referable to them) entails, for the Recipients responsible for such violations - where deemed necessary for the protection of company interests and compatibly with the provisions of the current regulatory framework - the application of the sanctions indicated in the Organizational Model mentioned .

7. Approval of the Code of Ethics and its maintenance over time

The Code of Ethics is approved by the Board of HUBRAINS.

Any future updates, due to regulatory adjustments or the evolution of civil sensitivity, will be approved by the Board of Directors of HUBRAINS and promptly disseminated to all Recipients. Verification of the adequacy of the Code of Ethics with respect to the sensitivity of HUBRAINS, its implementation and application is the responsibility of the Supervisory Body, of which HUBRAINS he gifted himself. The Supervisory Body may also act as promoter of proposals for integration or modification of the contents, also on the basis of the reports provided by the recipients.

8. Acceptance of the Code of Ethics

Every employee, collaborator, consultant and member of HUBRAINS examines and accepts this Code of Ethics, undertaking to respect it and to facilitate the work and control of the bodies responsible for its compliance.

Compliance with this Code is a fundamental requirement for all those who work in HUBRAINS . In particular, those who hold a coordinating or functional-hierarchical role with respect to others have the task of enforcing the Code of Ethics in their area of responsibility.

9. Communication and training

The Code of Ethics is brought to the attention of all stakeholders, through specific communication activities. In order to ensure the correct understanding of the Code of Ethics, the Supervisory Body defines a periodic communication / training plan aimed at promoting knowledge of the ethical principles and rules contained in the Code. Training initiatives can be different according to the role and responsibility of the collaborators.

10. Violations of the Code of Ethics

In the event of an ascertained violation of the Code of Ethics, the Supervisory Body reports the report and requests the application of any sanctions deemed necessary by the Board of HUBRAINS and to the Presidency. In the event that such violations concern one or more members of the Board of Directors or the President, the Supervisory Body will report the reports and the disciplinary sanction proposal for information to the Board of Directors, as a collegial body, for the eventual convening of the Assembly. of the shareholders.

The competent functions, activated by the aforementioned bodies, approve the measures, including sanctions, to be adopted in accordance with the regulations in force, ensure their implementation and report the outcome to the Supervisory Body.

Drafted on January 26, 2021