Art. 1

General provisions of application

1. This Code of Ethics (hereinafter, the “Code”) sets out the guiding principles of behavior of all subjects (hereinafter, the “Subjects” and, individually, the “Subject”) who, in any capacity, you will find at Studio Gullì (hereinafter the“Firm”) and specifies the duties of loyalty, impartiality, diligence, and industriousness that the Subjects must apply.
Each Subject avoids any act or behavior that violates or could lead to believe that the provisions of the law or regulation or those contained in the Code are violated accountants, to the impartiality of the activity of chartered accountants as well as to the respect of confidentiality obligations.
3. The Code applies to all those who will turn to the Firm under any form, full-time or part-time, in the form of subordinate employment or not subordinate, to trainees, to consultants and to persons authorized to attend the Firm to carry out studies or research.
4. The laws and ethical rules applicable to chartered accountants remain unaffected , to which the Subjects shall in any case conform, insofar as they are applicable to them and competence.

Art. 2

General provisions

Art. 3

Impartiality

1. Each Subject operates with impartiality, avoids favorable treatment and unequal treatment, refrains from applying undue pressure and rejects it, adopts initiatives and decisions with the utmost transparency and avoids creating or benefiting from privileged situations.
2. In relations with all those who are interested in the activity of the Firm in any capacity, each Subject does not undertake commitments or formulate personal promises which may condition the fulfillment of the official duties.
3. Each Subject, without prejudice to the right of association and the right to join political parties and trade unions, communicates to the owners of the Firm the membership of associations, circles or other bodies of any nature whose interests may influence the performance of the functions of office.

Art. 4

Integrity

1. Each Subject does not use the Firm to pursue ends or to achieve private and personal benefits.
2. Each Subject does not make use of the position he holds in the Firm to obtain utilities or benefits in external relationships, even of a private nature. In private relations, each Subject avoids declaring or implying his position in cases where such mention does not respond to objective needs.
3. Each Subject does not use information not available to the public or not made public, obtained even confidentially in the course of office activities, to make profits or private interests.
4. Each Subject avoids receiving benefits of any kind, which may be or appear such as to influence their independence of judgment and impartiality; moreover, it does not solicit or accept, for itself or for others, any gift or other benefit from all those who are in any case interested in the activity of the Firm or who intend to enter into a relationship with it, with the exception of gifts of modest value.
5. In the event that he receives unlawful pressure or is offered gifts, benefits or other benefits exceeding a modest value, each Subject is required to promptly notify the owners of the Firm.

Art. 5

Particular rules

1. Outside of the ordinary procedure for assigning files, each Subject does not solicit or receive communications intended for him, nor does he send unauthorized missives.
2. Each Subject participates only in meetings and meetings, even informal, relevant to the office activity in which he is authorized to take part; it also avoids unauthorized contacts with recipients, even indirect ones, of the Firm’s activity or with anyone who supplies or intends to supply goods or services to the Office.
3. Participation of Subjects in conferences, seminars and debates is authorized on the basis of the criteria of transparency, competence, opportunity and rotation, subject to a declaration regarding the amount of any reimbursement, token or compensation received for any reason, or regarding the use of particular benefits.

Art. 6

Conflict of interest

1. Each Subject takes steps to prevent situations of conflict of interest with the Firm and informs the owners of the Firm of any interests, including of an economic nature, that he, his spouse, relatives within the fourth degree or cohabiting subjects have in the activities or in the decisions within its competence.
2. In any case, each Subject abstains from participating in activities or decisions that determine such a conflict, and provides the owners of the Firm with any further information requested.
3. Each Subject refrains from participating, for a period of at least two years, in the discussion of matters that may involve the interests of their previous business associates or, except in the cases in which they are authorised, of their previous employers.
4. Each Subject abstains in any other case in which there are serious reasons of convenience or in which, also due to serious enmity, his or her participation in the discussion of the matter could generate distrust in the impartiality of the Firm.
5. Each Subject shall promptly inform the Firm’s owners of any contacts initiated, for the purpose of taking on assignments or activities outside the Firm, with all those who are interested, even if only potentially, in the Firm’s activity.
6. This Code commits each Person who ceases to work for the Firm not to be in a situation of conflict of interest with the Firm for a period of at least two years.

Art. 7

Confidentiality

1. Each Subject respects official secrecy and keeps confidential news and information learned in the exercise of their duties and which are not subject to transparency in accordance with the law and regulations.
2. Each Subject observes the duty of confidentiality even after termination of service.
3. In particular, each Subject does not provide information regarding preliminary investigations, inspections or investigations in progress at the Firm and does not release information relating to deeds stipulated or to be stipulated.
4. Each Subject consults only the documents and files to which he is authorized to access and makes use of them in accordance with his official duties, allowing access to those who are entitled to it and in compliance with the instructions given in the Firm.
5. Each Subject prevents the possible dispersion of data by observing the security measures established, keeping the documents entrusted with order and care and avoiding making useless copies.

Art. 8

Relations with the press – Accounting transparency and completeness
of information

1. Each Subject does not maintain relations with the press or with other means of information and abstains from any public statement that could affect the image of the Firm; if it is requested to provide clarifications or information by the press or other means of information, it shall promptly notify the owners of the Firm.
2. Accounting transparency is based on the truth, accuracy and completeness of the basic information for accounting records.
3. All actions and operations of the Firm must be adequately recorded and it must be possible to verify the decision-making, authorization and execution process.
4. For each operation, adequate supporting documentation of the activity carried out is kept in the records, in order to be able to carry out checks at any time which attest to the characteristics and reasons for the operation and identify the persons who authorised, carried out , recorded and verified the operation itself.
5. The Recipients are required to provide complete, transparent, understandable and accurate information, so that in setting up relations with the Firm, the stakeholders are able to make autonomous and aware decisions of the interests involved, of the alternatives and of the relevant consequences.

Art. 9

Related activities – Personnel policy

The Firm is committed to creating a serene working environment within it, in which everyone can work in compliance with the laws, principles and shared ethical values. The Firm enhances the professionalism of employees and collaborators, supporting their training, making training tools available to them, trying to develop and grow specific skills. It also undertakes to comply with workplace safety legislation and to promote safety in all places that make up the workplace itself.
– Each Subject informs the owners of the Firm of any writings and articles that it intends to publish in the fields of competence of the Firm.
– Each Subject does not perform other subordinate or self-employment activities, including consultancy in matters connected with those of the Firm’s competence.
– Each Subject does not carry out other external activities which conflict with the duties or which affect the correct performance of the official duties.

Art. 10

Relations between employees – Collaborators – Owner

Art. 11

Relations with the outside world, relations with the public administration, relations with political organizations and trade unions

Recipients must also comply with the rules of this Code in relations with the outside world. Relations with public institutions will be held only by persons authorized to do so.
All relations with the Public Administration must conform to the principles of diligence, transparency and honesty. The Recipients of this Code must behave in a manner inspired by the utmost correctness and integrity in relations with employees and representatives of public bodies, political forces and trade unions. Gifts and acts of courtesy and hospitality towards government representatives, public officials and public employees are permitted only when they are of modest value and in any case such as not to compromise the integrity or reputation of one of the parties and cannot be interpreted, as aimed at acquiring advantages improperly.

Art. 12

Relations with the judicial authorities

Relations with customers must be based on loyalty, transparency and confidentiality, and characterized by courtesy and professionalism, in order to consolidate the relationship of trust with customers and promote the Firm’s image with the public. The personnel, within the scope of their competences, must always keep themselves informed and updated in order to offer the customer satisfactory answers and favor informed choices. In this perspective, it is the Recipients’ responsibility to provide information that is as clear, complete and understandable as possible to the interlocutor.

Art. 13

Relations with customers

Relations with customers must be based on loyalty, transparency and confidentiality, and characterized by courtesy and professionalism, in order to consolidate the relationship of trust with customers and promote the Firm’s image with the public. The personnel, within the scope of their competences, must always keep themselves informed and updated in order to offer the customer satisfactory answers and favor informed choices. In this perspective, it is the Recipients’ responsibility to provide information that is as clear, complete and understandable as possible to the interlocutor.

Art. 14

Relations with suppliers

The selection of suppliers and the determination of the purchase conditions are based on an objective assessment of the quality and price of the good or service, as well as the guarantees of assistance and timeliness.

Art. 15

Sanction provisions

The provisions of this Code are an integral part of the contractual obligations assumed by the Recipients, or by the subjects having business relations with the company. Violation of the provisions of the Code may constitute a breach of contractual obligations, with all legal consequences, also with regard to the termination of the contract or of the assignment and any compensation for damages.

Art. 16

Updates of the Code

This Code may be updated on the basis of legislation and ethical principles that have arisen as well as on the basis of experience acquired from time to time.