Code of Ethics

Our Code of Ethics declares our commitment to promote the application of our Ethical Principles by our business partners and suppliers.

1. Strategies and behaviors

Insight Adv Ltd places the customer at the center of every strategic choice. The ambition to earn the esteem of customers takes the form of the Insight Adv Ltd's desire to:

put all the passion to satisfy customers, understand their desires and offer solutions that are always able to exceed their expectations;
live in the present but always with an eye to the future, looking for innovative products, services and solutions capable of anticipating the wishes of customers;
express the daily aspiration to identify and achieve new goals, both towards customers and towards the market. Being ambitious and competitive, being market leaders every day, always striving for excellence.

To make this possible, the people of Insight Adv Ltd are committed to working quickly, professionally, simply and reliably to earn the trust of customers day after day.

2. Company policy

The success of Insight Adv Ltd depends on the commitment to conducting a correct business policy and on the way of interacting with one's interlocutors and/or collaborators, i.e. not only employees, customers, commercial partners and suppliers, but also Authorities, institutions, communities, companies and environment.

The Insight Adv Ltd carries out its activity in full compliance with the law, above all supporting the respect of human rights. The principles on which the company policy is based represent a further commitment of the Insight Adv Ltd towards all those who interact with the company.

This corporate policy also applies to Insight Adv Ltd's relationships with its business partners, customers and suppliers, with whom it endeavors to promote the application and observance of its principles.

Insight Adv Ltd is aware that its commercial success also depends on its ability to adhere to and comply with corporate principles and, consequently, seeks to put these principles into practice with the utmost diligence to constantly improve the consistency of its action with respect to the same principles.

The Insight Adv Ltd requires all employees to know, share and respect with the utmost diligence the corporate principles listed below, as well as promote the application of these principles by collaborators, business partners and suppliers.

3. The creation of value

Insight Adv Ltd believes that in a market economy competition, exercised in an ethical manner, represents the best way to guarantee benefits and contribute to the company's commercial success.

Everyone's commitment must guarantee the best possible results.
The criteria that guide investments, purchases and commercial relationships are primarily of an economic nature, but also include social and environmental considerations.

4. Politics

The directors and employees of the Insight Adv Ltd cannot carry out political activities - excluding trade union activities - during working hours, or use the Company's assets or equipment for this purpose; they must also clarify that any political opinions expressed by them to third parties are strictly personal and therefore do not represent the opinion and orientation of the company.

5. Communication

The Insight Adv Ltd communicates openly and transparently to all the various interlocutors, within the limits of commercial confidentiality.

Relations between the Company and the mass media, as well as - more generally - communications to the various external interlocutors, are the exclusive responsibility of the company functions expressly delegated to do so and must be maintained in compliance with the communication policy defined by the company.

In any case, information and communications relating to the company and intended for the outside world must be accurate, truthful, complete, transparent and consistent with each other.

6. Customers

Insight Adv Ltd is committed to offering its clients safe and reliable products and highly professional services at good value for money.

The Insight Adv Ltd works trying to understand, anticipate and respond to the different needs of customers to offer them innovative products and services.

Insight Adv Ltd values the trust placed in it by clients and protects the information provided in accordance with applicable laws.

Employees, collaborators, business partners and suppliers involved in the commercial activity of Insight Adv Ltd, therefore, must:

scrupulously comply with the provisions of this Code relating to the management of customer relations;
align its conduct in relations with all customers with the principles of transparency, reliability, responsibility and quality;
ensure the quality and reliability of the services and products offered, monitoring that the services and products provided by third party suppliers in general fully comply with the quality standards of the Insight Adv Ltd;
provide the customer with all information on the contractual conditions and terms relating to the provision of company services, so that the customer is fully aware of it when finalizing the agreement;
be truthful in advertising communications;
adopt a behavior based on availability, respect, courtesy, in line with the standards of the Insight Adv Ltd, characterized by the highest professionalism;
pay particular attention to customer satisfaction activities, with a view to continuously improving the quality of the services and products offered, courteously collecting any suggestions or complaints from customers and making use of suitable and timely communication systems for this purpose.

7. Employees and collaborators

Relations with and between employees and collaborators are based on respect for individuals and their human rights.

The Insight Adv Ltd adopts a policy based on equal opportunities in consideration of the diversity of individuals.

Insight Adv Ltd helps its employees develop to their full potential through training and development activities.

Insight Adv Ltd promotes employee participation in incentive stock plans.

Full respect for the employee and non-discrimination in the workplace for reasons of sex, race, language, religion, political opinions, trade union membership, social and personal status are among the founding values adopted by Insight Adv Ltd.

Professional development and growth are two important objectives of the policy adopted to manage the Company's resources. The Insight Adv Ltd, in fact, aims to attract, reward and develop people of exceptional quality to whom it offers stimulating responsibilities and development opportunities. Attention is paid in particular to the creation of new professional skills, extended to all levels to facilitate the management of the continuous changes required by the market and by the role of the Insight Adv Ltd in society. In this direction Insight Adv Ltd contributes to the growth of skills through significant investments in training, job rotation and mobility, with the construction of a real network of professionals (including programmers, graphics & web designers, photographers, illustrators and journalists), each with their skills and professional experience, who are offered the opportunity to collaborate in the implementation of individual projects or groups of projects of the Insight Adv Ltd.

In order to offer its own contribution to the fight against social hardship, the Insight Adv Ltd periodically organizes and finances free professional training courses for minors and adolescents at risk, unemployed young people and women, in order to facilitate their entry into the world of work.

In the various stages of managing relations with its employees, Insight Adv Ltd is therefore inspired by the following principles.

7.1. Personnel selection

The Insight Adv Ltd offers the same job and/or professional growth opportunities without any discrimination, starting from the moment of personnel selection.

The assessment of the candidates participating in the selection is focused on verifying the fulfillment of the professional, behavioral and aptitude requirements envisaged by the profile requested, with respect for the candidate's dignity, personality, private sphere and opinions.

Favoritism or forms of patronage are not permitted (for example, whoever selects or participates in the selection must not be in a situation of conflict of interest with the candidate).

7.2. Establishment of the employment relationship

Hiring takes place with a regular employment contract in full compliance with the law and the CCNL applied, favoring the worker's integration into the work environment.

Employees are aware of the terms and conditions of their employment, and the Company provides fair and reasonable wages and conditions.

7.3. Personnel Management

Insight Adv Ltd offers the same career opportunities to those who possess the characteristics required for access to functions, without any discrimination and on the basis of merit criteria, acquired professional competence and, in any case, on the basis of strictly professional parameters.

The Insight Adv Ltd considers personnel training and constant updating on specific issues (for example, occupational safety and hygiene) a primary requirement of the company.

Insight Adv Ltd promotes team spirit and mutual collaboration and expects employees, at all levels, to work together to maintain a climate of mutual respect for each other's dignity and reputation.

7.4. Harassment and discrimination in the workplace

Insight Adv Ltd expects no harassment of any kind against employees, suppliers, customers or visitors in its internal and external business relationships. By harassment we mean any form of intimidation or threat that is an obstacle to the peaceful performance of one's duties or the abuse by the hierarchical superior of the position of authority.

The Insight Adv Ltd also demands that in internal and external working relationships there is no discrimination of any kind against employees, suppliers, customers or visitors related to differences of sex, race, language, religion, political opinions, union membership, personal or social conditions.

Whoever, in carrying out his activity in favor of the Company, believes that he has been subjected to harassment or that he has been discriminated against for any reason, can report the incident to the Supervisory Body. Any act of retaliation against an employee who refuses, complains or reports such unfortunate facts is prohibited.

7.5. Abuse of alcohol or drugs

The Insight Adv Ltd prohibits each employee or collaborator from working while drunk or in a state of consciousness altered by the intake of narcotic or hallucinogenic substances or substances which in any case affect the regular performance of the work activity. In any case, the Insight Adv Ltd discourages the abuse of alcohol and the use of drugs by each employee or collaborator even outside working hours and regardless of the influence of such conduct on the regular performance of work .

7.6. Smoke

The Insight Adv Ltd undertakes to guarantee the safety and health of its employees, without prejudice to the smoking bans established by law in places where this could endanger the safety of people and the healthiness of the environments.

7.7. Privacy protection

The Insight Adv Ltd complies with the applicable legal requirements regarding the processing of personal data. With particular regard to the processing of personal data of workers, the Insight Adv Ltd prepares specific precautions aimed at informing each employee about the nature of the personal data processed by the company, the methods of treatment, the areas of communication and, in general, on any data relating to your person.

8. Conduct of employees and collaborators

Insight Adv Ltd expects all employees to act with honesty, integrity and impartiality.

We will not tolerate any form of bribery, including improper offers and payments made to or from employees.

Employees must avoid any contact that could lead to, or suggest, a conflict of interest between their business and that of Insight Adv Ltd.

Employees must avoid accepting gifts or hospitality that could make them feel obligated to others.

8.1. Prohibition of Corrupt Practices

Insight Adv Ltd does not tolerate any form of bribery, including improper payments or illegal offers to pay for or from employees.

In relations with third parties, including the Public Administration, in Italy or abroad, Insight Adv Ltd employees, collaborators and/or representatives, in any capacity, are not permitted to pay or offer, directly or through third parties, sums of money or gifts of any kind and entity to subjects external to the Insight Adv Ltd, whether they are public officials or persons in charge of a public service, government representatives, public employees or private citizens, both Italian and from other countries, with which Insight Adv Ltd has commercial relations , to compensate or repay them for an act of their office or to achieve the execution of an act contrary to the duties of their office.

Acts of commercial courtesy, such as gifts or forms of hospitality, or any other form of benefit (even in the form of donations), are permitted only if of modest value, in accordance with custom and such as not to compromise the integrity and reputation of the parties ; in any case, such deeds must not be able to be interpreted, by a third party and impartial observer, as deeds intended to obtain advantages and favors in an improper manner. In any case, such acts must always be authorized and documented.

8.2. Diligence and good faith

Employees and collaborators, in any capacity, of the Insight Adv Ltd must act loyally and in good faith, respecting the obligations signed in the employment or collaboration contract and ensuring the required services, as well as knowing and observing the ethical rules contained in this Code, own conduct to mutual respect and cooperation and mutual collaboration.

All actions, operations and negotiations and, in general, the behaviors implemented in the performance of the work activity, must be based on the principles of honesty, correctness, integrity, transparency, legitimacy, clarity and mutual respect as well as be open to checks and controls according to current regulations and internal procedures.

All activities must be carried out with commitment and professional rigor. Everyone must provide an adequate professional contribution to the responsibilities assigned and must act in such a way as to protect the prestige of the company.

Insight Adv Ltd personnel, regardless of the function performed and/or the level of responsibility assumed, must know and implement the provisions of the company in terms of environmental protection, occupational safety and hygiene and privacy protection.

8.3. Conflict of Interest

Employees and collaborators, in any capacity, of Insight Adv Ltd must refrain from carrying out activities that are even potentially in conflict with the interests of the company or its customers.

By way of example, the following could constitute cases of conflict of interest:

the existence - evident or hidden, direct or indirect - of economic or financial interests of the employee or collaborator or his family members in the activities of suppliers, customers, competitors;
the exploitation of one's functional position for the realization of interests even potentially in conflict with those of the company;
the use of information acquired in carrying out work activities for one's own benefit or that of third parties in contrast with the interests of the company or its customers;
the performance of work activities of any kind (services and intellectual services) for customers, suppliers, competitors and/or third parties in conflict with the interests of the company or its customers;
the conclusion, completion or start of negotiations and/or contracts - in the name and/or on behalf of the company - which have as counterpart family members or associates of the employee or collaborator, or legal entities of which he is the owner or to which he is still interested;
the acceptance of money or other benefits or favors from natural or legal persons who are or intend to enter into business relations with the Insight Adv Ltd.

It is forbidden to personally take advantage of business opportunities that one becomes aware of in the course of carrying out one's duties within the company.
Before accepting a consultancy, management, administration or other assignment in favor of another person potentially suitable to generate a conflict of interest, or in the event that a situation of conflict of interest arises, each employee is required to communicate it to the Company Management, according to the provisions of the company policies. If the report does not give a result or the employee feels uncomfortable in contacting the Administrative Director, he reports it to the Supervisory Body. Likewise, each employee is required to communicate, in the same manner as above, situations of conflict of interest in which other employees find themselves and of which they have become aware.

8.4. Gifts or other form of benefit/utility

Employees who receive gifts, or other forms of benefit/utility, not directly attributable to normal courtesy relationships, must take all appropriate steps to refuse said gift or other form of benefit/utility, in any case in compliance with company policies.

8.5. Protection of corporate assets and the working environment

Each employee is required to safeguard the company's assets, guarding movable and immovable property, technological resources and IT supports, equipment, company products, information and/or the know-how of Insight Adv Ltd.

In particular, each employee must:

use corporate assets according to corporate policies, scrupulously observing all security programs to prevent unauthorized use or theft;
avoid improper use of corporate assets that could cause damage or reduce efficiency, or in any case contrary to the company's interests;
maintain the secrecy of confidential information concerning the company or business partners of the company, avoiding revealing it to third parties;
scrupulously comply with the provisions of the corporate security policies, in order not to compromise the functionality and protection of the IT systems;
not to send threatening or abusive e-mail messages, not to use impolite or unprofessional language, not to make inappropriate comments that may offend a person and/or damage the corporate image;
keep and not disclose to unauthorized third parties your personal password and your access code to company databases;
do not reproduce company software for personal use or use the supplied tools for private purposes;
not to use corporate communication systems (email, intranet, etc.) and the web for purposes other than professional and service ones.

Each employee is responsible for protecting the resources entrusted to him and has the duty to promptly inform his direct managers of potentially harmful events for the Insight Adv Ltd.

The principles set out above are also applicable to collaborators, to the extent that they can be concretely involved in safeguarding the company's assets, insofar as they are allowed to use the company's equipment, resources or assets (as better described above).

8.6. Image protection

The good reputation and/or image of Insight Adv Ltd is an essential intangible asset.

Insight Adv Ltd employees undertake to act in accordance with the principles set out in this Code in relations between colleagues, customers, suppliers and third parties in general, maintaining a decent demeanor in accordance with the standards common to companies of the size and importance of Insight Adv Ltd.

9. The environment

The Insight Adv Ltd undertakes to promote actions that can ensure sustainable development and environmental protection:

Processes are put in place to actively improve the efficiency with which limited resources (such as energy, water, raw materials) are used.
Management, operational and technical controls are put in place to minimize the release of emissions dangerous to the environment.
The use of business practices that reduce the environmental impact of the Insight Adv Ltd's activities is promoted.
Innovative improvements in products and services that deliver environmental and social benefits are supported.

Environmental protection and the preservation of natural resources are high priority corporate objectives. Insight Adv Ltd has always been attentive to environmental issues, a sensitivity that is expressed through specific initiatives, aimed at protecting and respecting the territory and nature. New ideas in which technological innovation is combined with environmental protection.

Each employee, collaborator, commercial partner and supplier, in carrying out their activity, must collaborate to achieve exemplary results in this sector.

10. Community and society

The Insight Adv Ltd accepts the responsibility to engage with the community and to invest in society in order to effectively use its resources, supporting projects and activities aimed at the development and growth of the economic, social and cultural well-being of the territory.

Insight Adv Ltd has always been very attentive to social issues and continues to assume responsibility in the social field, providing its contribution in various sectors. Consistent with the philosophy that has always distinguished it, the Insight Adv Ltd offers its contribution in the implementation of all those projects that are closest to the heart of the local communities and which offer the possibility of improving people's lives and of overcoming and contrasting all forms of discomfort. The Insight Adv Ltd also promotes Corporate Social Responsibility which is developed through a set of choices and strategies which, while respecting the company, increase the economic value of the company itself.

11. Health and safety

Insight Adv Ltd is committed to safeguarding the health and safety of its clients, employees, contractors and the community in which it operates.

In compliance with current legislation on health and safety, the Insight Adv Ltd undertakes to disseminate and consolidate a culture of health and safety in the workplace by developing risk awareness and promoting responsible behavior by all its employees; it also works to preserve - also through training plans, preventive actions, periodic checks - the health and safety of workers.

12. Business partners, collaborators and suppliers

Insight Adv Ltd builds mutually beneficial relationships with its business partners, contractors and suppliers.

The Insight Adv Ltd promotes the application of its principles of business conduct also by its business partners, collaborators and suppliers.

12.1. Relations with collaborators

The company's external collaborators, however called ("collaborators", "consultants", "representatives", "agents"; hereinafter, for the sake of brevity, the "Collaborators"), are required to comply with the principles contained in the Code.

Each employee, in relation to their duties, will take care of:

scrupulously observe the operating practices and internal procedures relating to the selection and management of relations with Collaborators;
select, as company collaborators, only people and companies that are recognized as qualified, with an excellent reputation and/or for which we have not come to know of behaviors in conflict with the principles of this Code;
promptly contact the Administrative Department in the event of any violations of the Code by Company collaborators; if the report does not give a result, or the employee feels uncomfortable in contacting the Administrative Department to make the report, the employee reports it to the Supervisory Body;
expressly mention, in all contracts entered into with Collaborators, regardless of the nomen iuris adopted for such contracts ("collaboration", "consultancy", "agency", "private agreement"), the obligation to comply with the principles of the Code, to maintain behaviors suitable for preventing the commission, even attempted, of the crimes in relation to which the sanctions provided for in Legislative Decree 231/2001 apply, sanctioning any non-fulfillment of these obligations with the provision of the faculty for the Insight Adv Ltd to resolve the contract, obviously without prejudice to the right to compensation for any damages suffered.

12.2. Relations with suppliers

The Insight Adv Ltd bases its conduct in relations with suppliers on the principles of transparency, equality, loyalty and competition.

In particular, Insight Adv Ltd employees must:

scrupulously observe the operating practices and internal procedures relating to the selection of suppliers and the management of relations with them;
obtain the collaboration of suppliers in ensuring the satisfaction of customer needs in terms of quality, cost and delivery times of goods or provision of services;
observe and respect, in the supply relationships, the applicable legal provisions and the contractual conditions;
in relationships with content providers, do not purchase images and/or content that conflict with the provisions of the law (e.g. pedophilia);
observe the principles of transparency and completeness of information in correspondence with suppliers;
avoid receiving money or other utilities or benefits from anyone other than Insight Adv Ltd for the performance of an act of one's office or contrary to one's official duties;
avoid giving or receiving, directly or indirectly, gifts, presents, hospitality, or other advantages, unless the value of the same does not exceed the limits of a normal courtesy relationship.

12.3. Choice of suppliers

The purchasing processes are based on the search for the maximum competitive advantage for the Insight Adv Ltd and on the protection of the quality standards of the Insight Adv Ltd itself.

To this end, the functions participating in these processes must:

granting suppliers in possession of the necessary requisites equal opportunities to participate in the selection;
verify, also through the request for delivery of suitable documentation, the existence of subjective requirements relating to the professionalism and integrity of the suppliers;
verify, also through the request for delivery of suitable documentation, that the suppliers participating in the selection have the means, including financial ones, organizational structures, skills, know-how, quality systems and resources adequate for the needs and quality requirements of the Insight Adv Ltd.
In particular, contractual clauses are introduced in contracts with suppliers which provide for declarations by the supplier regarding possession of the aforementioned subjective and organizational requirements, know-how and resources adequate to the needs and quality standards of the Insight Adv Ltd, as well as relating to the existence and effective implementation of adequate corporate quality systems.

12.4. Integrity and independence in relations with suppliers

Relations with suppliers are governed by common principles and are subject to constant monitoring by the Insight Adv Ltd.

In particular:

long-term binding projects based on short-term contracts that require continuous renewals with price revisions, or consultancy contracts, however denominated, without an adequate transfer of know-how must be avoided;
it is not considered correct to induce a supplier to stipulate an unfavorable contract by giving that supplier an unfounded hope in a subsequent more advantageous contract.

To ensure maximum transparency and efficiency of the purchasing process, the Insight Adv Ltd prepares and/or adopts:

the separation of roles - where practically practicable - between the unit requesting the supply and the unit stipulating the relative contract;
operating procedures/instructions that regulate the duty to adequately document the choices made (so-called "traceability");
the retention of information and official documents relating to the selection of suppliers as well as contractual documents for the periods established by current regulations and referred to in the internal procedures relating to purchases;
the principle according to which no payment to the supplier can be made:
- in cash or by means of bearer securities;
- to a person other than the supplier, with the exception of cases in which payment must be made to third parties, other than the supplier, provided that this is done in a legitimate, transparent and documented manner (for example, in the event of a credit assignment by of the supplier), as well as on current accounts opened with foreign credit institutions, when the supplier is not based abroad, except in exceptional cases which must be adequately justified and documented, it being understood that the relative payments must be duly authorized by the Administrative Department .

Specific clauses are expressly provided for in the individual supply contracts regarding the knowledge and the obligation to observe, on the part of the supplier, the principles contained in this Code of Ethics, the obligation to behave in a manner suitable for preventing the commission, even attempted, of crimes in relation to which the penalties provided for in Legislative Decree 231/2001 apply, as well as express termination clauses that can be enforced by Insight Adv Ltd in the event of non-fulfilment of these obligations, obviously without prejudice to the right to compensation for any damages suffered.

The Insight Adv Ltd brings the content of this Code to the attention of suppliers and encourages all suppliers to adopt an organisation, management and control model pursuant to Legislative Decree 231/2001, as well as a code of ethics, in all their companies and within of their supply chains.

13. Relations with the Public Administration

The relations of the Insight Adv Ltd with the local, national, community and international Public Administration, or in any case relating to relations of a public nature, must be inspired by the strictest observance of the applicable legal and regulatory provisions as well as the general principles of fairness and loyalty as above declined and company procedures.

The assumption of commitments and the management of relations, of any kind, with the Public Administration and/or relations of a public nature are reserved exclusively to the corporate functions responsible for this and duly authorized.

Without prejudice to all the obligations imposed by current legislation on the subject, Insight Adv Ltd and its employees and/or collaborators will abstain, during business negotiations, requests or commercial relations with the Public Administration, as well as in the event of controls/ inspections/verifications by the competent Authorities from time to time, from undertaking (directly or indirectly) the following actions:

privilege in any way or offer employment and/or commercial opportunities to Public Administration personnel involved in the negotiation, relationship or controls/inspections/verifications, or their family members;
offer or in any way provide, accept or encourage gifts, presents or any other benefit to personnel of the Public Administration, or their family members, except in the case in which they are acts of commercial courtesy of modest value, compliant with custom and such as not to compromise the integrity and reputation of the parties;
solicit or obtain confidential information that could compromise the integrity or reputation of both parties or that in any case violate equal treatment and the public disclosure procedures activated by the PA;
adhere to any request for contributions and sponsorships, which may influence business negotiations or favor the company in the event of checks/inspections/verifications by the Authorities.

In particular, requests for contributions and sponsorships will be evaluated only if proposed by non-profit organizations and associations, or if they are of high cultural or charitable value (by way of example, contributions and sponsorships may concern initiatives in the social, environmental, sport, entertainment, culture, art). In any case, in choosing the proposals to join, the Insight Adv Ltd pays particular attention to any possible conflict of interest of a personal or corporate nature.

Employees who receive offers of gifts or benefits not permitted by a specific procedure are required, according to the established procedures, to refuse them and to immediately notify the Administrative Department which assesses the compliance of the offer with the principles of the Code.

14. Internal Controls

By "internal controls" we mean all the tools necessary or useful for directing, verifying and pursuing the company's activities with the aim of ensuring compliance with the laws and company procedures, protecting company assets, effectively and ethically managing social activities and clearly provide true and correct information on the company's equity, economic and financial situation, as well as identify and prevent the risks that the company may incur.

The Insight Adv Ltd intends to use the highest standards of internal controls and it is its task to disseminate, at all levels, an internal culture characterized by awareness of the existence of controls and oriented towards the exercise of the control itself.

The internal control system of Insight Adv Ltd is subject to formal periodic verification and the results of these verifications are brought to the attention of the Administrative Department.

Insight Adv Ltd employees must, as far as they are responsible:

contribute to the correct functioning of the control system;
responsibly guard the company assets instrumental to the activity carried out, whether they are tangible or intangible, and not make improper use of them.

15. Supervisory Body

In order to supervise compliance with the Code, a commission has been set up, called the Supervisory Body, made up of a representative designated by the company and one designated by the workers among the employees and collaborators of the Insight Adv Ltd.

16. Anti-Money Laundering

Employees and Collaborators of Insight Adv Ltd must not, in any way and under any circumstances, receive or accept the promise of cash payments or run the risk of being implicated in events relating to the laundering of money deriving from illegal or criminal activities.

Before establishing relationships or stipulating contracts with non-occasional suppliers and other partners in long-term business relationships, they must ensure the moral integrity, reputation and good name of the other party.

Insight Adv Ltd undertakes to comply with all national and international anti-money laundering rules and regulations.

17. Confidential information and privacy protection

Each employee, collaborator, commercial partner and supplier of the Insight Adv Ltd is required to protect the privacy and confidentiality of the information relating to the company, learned in the course of or during the activities performed on behalf of the Insight Adv Ltd.

In compliance with the law, all information, knowledge and data acquired or processed by employees, collaborators, commercial partners and suppliers through their activities cannot be used, communicated or disclosed without the express authorization of Insight Adv Ltd.

Each employee, consultant, business partner and supplier must therefore:

acquire and process only the information and data necessary and directly connected to one's own activity;
keep said data/information in such a way as to prevent unrelated third parties from gaining knowledge of it;
communicate and disclose the data/information within the framework of the procedures established by the company and with the prior authorization of the Insight Adv Ltd through the person delegated to do so;
evaluate and determine the confidential nature of the information in accordance with the requirements of the procedures established by the Insight Agency;
observe the confidentiality obligations even after the termination of the relationship with the Insight Adv Ltd, in accordance with current legislation and/or the contractual commitments previously undertaken.
The activity of the Insight Agency requires the processing of data (by this meaning any operation or set of operations, carried out even without the aid of electronic instruments, concerning the collection, registration, organization, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of data, even if not recorded in a database ) subject to protection by current legislation on privacy.

The Insight Adv Ltd is particularly attentive to the aspects concerning the privacy of its employees/customers/suppliers and of any other subject interested in the processing of their personal data by the company.

Specific security measures are observed to prevent the loss, illicit or incorrect use of the data being processed by the company and/or unauthorized access to the company's website.

The processing of personal data is permitted only to authorized personnel and in compliance with the rules and procedures established in accordance with current legislation.

The Insight Adv Ltd undertakes to protect the information and data relating to its employees, consultants, business partners, suppliers, customers and third parties, and to avoid any improper use of the same.

18. Sanctions

Observance of the rules contained in the Code constitutes fulfillment by Insight Adv Ltd employees of the obligations established by art. 2104, paragraph 2, civil code 5 (obligations of which the content of the same Code represents a substantial and integral part), as well as an essential part of the contractual obligations envisaged with reference to collaborators, commercial partners and suppliers.

As far as Insight Adv Ltd employees are concerned, the violation of the aforementioned rules will constitute a breach of the obligations deriving from the employment relationship and a disciplinary offence, with all legal consequences, also with regard to the conservation of the employment relationship, and this regardless of any criminal relevance of the behaviors assumed and/or from the establishment of a criminal proceeding where a crime occurs.

The Insight Adv Ltd undertakes to foresee and impose, with coherence, impartiality and uniformity, sanctions proportionate to the respective violations of the Code and compliant with the provisions in force regarding the regulation of labor relations.

In the event of violations of the Code by Insight Adv Ltd employees, the company shall impose the most appropriate disciplinary measures against the perpetrators of the censured conduct, and the disciplinary measures compliant with the provisions of the applied collective bargaining agreement, in compliance with the art. 7 of the law of 20 May 1970, n. 300 and current legislation.

The disciplinary measures that can be imposed are according to the seriousness of the infractions:

verbal reminder;
written warning;
fine up to a maximum of three hours;
suspension (from service and salary) up to a maximum of three days, except in the case of non-disciplinary precautionary suspension;
dismissal.

In the event of news of violations of the Code emerging as a result of reports from employees, the Supervisory Body of Insight Adv Ltd informs the Administrative Department. The latter, following an appropriate analysis of the violations reported, decides on the possible existence or otherwise of such violations.

During the assessment phase, the charge will be notified to the employee in advance and he will also be guaranteed a reasonable deadline for replying in order to defend himself.

Once the violation has been ascertained, a disciplinary sanction will be imposed on the perpetrator, in agreement with the Supervisory Body itself, proportionate to the seriousness of the violation committed.

It is understood that the procedures, provisions and guarantees provided for by art. 7 of the Workers' Statute regarding disciplinary measures.

If the violation of the provisions of the Code is carried out by a Person who is not an employee of the Insight Adv Ltd (for example, a self-employed worker, supplier or other person linked by contractual relationships with the company), the right to termination of the related contract or withdrawal for just cause from the same, without prejudice to the right to compensation for any damages suffered, and this regardless of the possible criminal relevance of the behaviors undertaken and/or the establishment of a criminal proceeding where a crime occurs.

Code for ethical purchases

The following Code of Ethical Purchasing should be read in conjunction with our Code of Ethics, of which it forms an integral part, and has been developed to promote safe and fair working conditions, and the responsible handling of environmental and social issues in the Insight Adv Ltd supply chain .

The Code was developed following consultations with employees, contractors, business partners, suppliers and customers. It sets out the standards we intend Insight Adv Ltd and our suppliers to achieve over time.

The principle of continuous improvement is applied in all aspects of the Code.

In accordance with the implementing provisions of the Code, and as a condition of doing business, Insight Adv Ltd will require Tier 1 suppliers to acknowledge their understanding and acceptance of the principles of our Code, and to confirm compliance with them.

Insight Adv Ltd will work closely with its suppliers to implement the Code, which may include joint audits and site visits to continuously evaluate and verify enforcement performance.

Insight Adv Ltd encourages all suppliers to adopt the principles of the Code throughout their businesses and within their supply chains.

1. Child labor

Personnel below the minimum age required to carry out a working activity are not employed.

Minors (persons under the age of 18) are not employed for any dangerous or night work, or in any work activity that is contrary to the personal development of the minor.

Where a minor is employed, primary attention should be paid to the interests of the minor.

Maximum contribution, support and development are made to the policies and programs that assist any child labor or child labor fund.

2. Forced labour

No form of forced, bonded or compulsory labor is used, and employees are free to leave their jobs upon notification within a reasonable time. Employees are not required to deposit money or deposit their identification documents with their employer.

3. Health and safety

A healthy and safe working environment is provided to employees, consultants, temporary workers, partners or other subjects involved in the company's activities, in accordance with international standards and national laws. There are procedures to ensure that health and safety obligations are communicated to those who are required to apply them.

The delivery of goods and the provision of services are carried out in compliance with the general principles of risk prevention for health and safety.

Procedures are implemented to ensure that employees are able to fulfill the health and safety obligations associated with their activities and responsibilities.

Where an employer provides housing, it must be clean, safe, and accommodate the essential needs of employees.

Adequate information and training is provided to employees to deal with accidents, health and safety issues and emergency situations (where foreseeable). There are tools to record, analyze and draw ideas for improvement from any accidents and emergency situations.

4. Freedom of Association

Transparent and direct communication between employees and management is considered the best method for building working relationships and solving problems.

To the extent permitted by applicable law, all employees are free to join or not to join trade unions or similar external representative organisations.

5. Discrimination

Any discrimination in hiring, terms of employment, compensation, access to training, promotions, termination or retirement procedures and decisions is prohibited.

6. Disciplinary practices

Employees are treated with respect and dignity. Any physical or verbal abuse or harassment and other threats or forms of intimidation are prohibited.

7. Working hours

Employee working hours do not exceed the maximum limit established by national laws and the working week does not exceed 60 hours, including overtime.

In exceptional circumstances, where this hourly limit is exceeded, the hours worked cannot be excessive. Overtime must be remunerated with increased compensation and employees must have at least one day off per week.

8. Payment

Employees are aware of the terms and conditions of their work, and fair and reasonable wages and conditions are provided.

9. Individual behavior

We do not tolerate any form of bribery, including illegal offers of payments to or from employees, suppliers, customers, organizations or individuals.

10. Environment

Legislation and international standards for the management of environmental impacts are respected.

Processes are in place to actively improve the efficiency with which finite resources (such as energy, water, raw materials) are used including management, operational and technical controls to minimize the release of environmentally hazardous emissions.

Appropriate measures are put in place to improve the environmental performance of products and services as they are used by the end user, such as considering energy efficiency and end use of the product or service at the design stage.

Innovative improvements in products and services that deliver environmental and social benefits are supported.

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