CODE OF ETHICS
1. Recitals
Hager & Partners (hereinafter "H&P" or the "Firm") is a professional association of chartered accountants and lawyers with offices in Bolzano, Milan and Rome.
The Firm adopts a "Code of Ethics" to make compliance with current legislation more effective, efficient and controllable and to proclaim the values the organization protects and pursues in every area of its professional activity.
The rules of the Code of Ethics are binding for all professionals, employees and collaborators of the Firm.
The Code of Ethics is disclosed also outside the Firm. Any person, natural or legal, organization, body or association, public or private, who comes into contact with the Firm shall be informed about the Code of Ethics, undertakes to respect it and can ask the Firm to comply with it, internally as well as in relation with third parties.
The Firm monitors compliance with the Code of Ethics, updates it and adopts tools to control its effectiveness, sanctioning non-compliant conduct.
2. GENERAL VALUES AND PRINCIPLES
The Firm's professionals, employees and collaborators as well as those who, for several reasons, carry out activities for the Firm, shall operate with honesty, decorum, fairness, transparency, loyalty, competence and diligence.
The Firm guarantees for the confidentiality of information and documents received or drafted in the context of its professional activity.
The Firm works independently and autonomously, to safeguard the interests and rights of the client, within the limits and conditions provided for by law.
Personal and professional relationships within the Firm are in line with the principles of collaboration and trust. The Firm encourages and promotes appropriate and polite behaviour, consistent and appropriate with respect to the roles and functions that each person exercises or holds.
The Firm recognizes, respects and safeguards the attitudes, character and inclinations of people. Talent and commitment are valued and rewarded, both from an economic point of view and in terms of career paths.
Personal and professional growth is encouraged. Respecting the character and personality of each individual, the Firm stimulates and encourages proactive behaviour in overcoming professional and character limits that could prevent or hinder the achievement of the standards of professionalism expected by the clients.
The Firm provides a safe and suitable working environment for the activity carried out.
The Firm invests in the research for organizational solutions aimed at a reasonable balance between professional activity and private life.
The partners of the Firm (hereinafter "Partners") shall set an example. They should not demand behaviours that they themselves do not adopt. The Partners have the responsibility to create and maintain a healthy and productive work environment, to build relationships based on trust and transparency, to encourage the consolidation of team spirit, to ensure that the rules apply to everyone, without discrimination.
The Firm promotes a responsible and sustainable use of every resource, respecting the environment and according to a logic of cost containment.
The career paths of professionals, employees and collaborators are governed by the principles of competence, commitment, responsibility, proactivity, seriousness and compliance with the Code of Ethics.
Any form of discrimination, with particular reference to gender, political or religious beliefs, geographical origin, ethnic or linguistic belonging, is prohibited and sanctioned.
3. COMPLIANCE WITH LAW
Rules of professional ethics and conduct
The Firm respects and undertakes to ensure compliance with the principles and rules provided for by the Code of Ethics for Lawyers and the Code of Ethics for Chartered Accountants and Accounting Experts.
Environment and safety
The Firm respects and undertakes to ensure compliance with the legislation concerning environment and safety at work. Anyone who works within the Firm, even if only temporarily, is informed about health risks, safety measures and risk prevention measures.
Safety and protection of personal data – confidentiality and secrecy obligations
The Firm complies with current legislation concerning the protection and processing of personal data. Suitable measures are identified and adopted to prevent the risk of dispersion, loss, improper disclosure and unavailability of the personal data processed.
The Firm appoints a data protection officer ("DPO") pursuant to art. 39 of EU Regulation 2016/679 ("GDPR"). A register of processing operations -pursuant to art. 30 GDPR- is adopted, monitored and updated by the data processors with the assistance of the DPO. All information on the processing of personal data is provided promptly, in writing.
The DPO is appointed according to the principle of competence and independence.
Any person who processes personal data on behalf of the data processors is appointed in writing as "data processor".
The measures relating to the protection and processing of personal data are updated and monitored periodically.
Professional secrecy is safeguarded and protected.
All information and documents relating to professional activity are treated confidentially and with discretion.
Anti-money laundering
In carrying out its professional activities, the Firm complies with the provisions of anti-money laundering obligations. Specialized personnel are identified and trained to take care of every related fulfilment. The Firm guarantees adequate training programs for professionals and employees.
The Firm adopts internal procedures for the handling of inspections by the public authorities.
Conflict of interests
Anyone who works for the Firm must operate ensuring independence from pressures or conditioning, including personal ones, which may affect the client's interest.
4. QUALITY STANDARDS
Criterion of excellence
The Firm intends to stand out as the best professional reality in the sector. The parameter for evaluating the quality of the service is not limited to that of an average attentive, scrupulous and diligent professional: H&P aims for excellence, the use of specialized skills, the search for innovative solutions, maximum speed of action, organizational efficiency and a multidisciplinary approach.
Personnel recruitment
The Firm recruits and selects only personnel in possession of the qualifications, skills and experience consistent with the type of tasks or assignments to be carried out.
Work organization and career paths
Anyone who works for the Firm is required to carry out his/her activities with competence, diligence, commitment and promptness.
Career paths valorise personnel who expand their skills, know and correct their limitations, acquire or consolidate complementary skills, develop new services, create or strengthen customer relationships, propose new initiatives and take care of their professional updating in a targeted and efficient way.
The workloads are distributed according to a criterion of competence, efficiency, experience and spread of knowledge, also in consideration of the remuneration system.
The degree of autonomy and responsibility of each professional, employee and collaborator is decided in accordance with his or her role and the nature of the task or office assigned, combining an adequate level of control with the enhancement of autonomy and responsibility.
Innovation and updating
The Firm researches and adopts the most modern technological and organizational solutions.
The Firm is proactive in the creation of specialized know-how, with particular reference to the new frontiers in the technological, financial, economic and socio-political areas.
In addition to the consolidation of the traditional skills that characterize the sector, the Firm invests to expand its services in increasingly strategic business segments such as artificial intelligence, environmental compliance, energy efficiency, internationalization, sustainability reporting as well as enterprise crisis prevention measures.
Internationalization and use of languages
H&P is a firm with an international vocation, capable of managing a large number of tax and legal aspects concerning relationships, transactions, conflicts and any other case of cross-border dimension.
H&P aims to consolidate trilingualism (Italian, German and English) in the provision and execution of its services.
5. PERSONAL RELATIONSHIPS – PROTECTION OF SPECIAL CONDITIONS
The Firm promotes personal relationships based on fairness and mutual respect, regardless of roles and internal hierarchy.
Anyone who works for the Firm is required to behave with others in a loyal, transparent and appropriate manner, helping to consolidate frank and honest relationships. Each professional, collaborator and employee is required to support those who ask for their help and assistance, compatibly with their commitments.
Prevarications, offensive or denigrating attitudes, the use of allusive or inappropriate expressions, any form of threat and retaliation are prohibited.
The Partners work to create and maintain a cooperative dimension of work, enhancing personal talents and inclinations.
Anyone who finds him-/herself in conditions of difficulty, disability (permanent or temporary, physical or mental), is put in the best conditions to continue to carry out his/her job, taking care of his/her dignity and needs.
Forms of discrimination, sanctions, retaliation and any other form of prejudice against those who are temporarily unable to carry out their job for justified reasons, such as in cases of maternity, paternity, illness and accident, are prohibited.
The Firm ensures that all collaborators have periods of rest and holidays of reasonable duration, taking into account current commitments and deadlines, the need to maintain continuity of service and the period of the year.
The relationship with the customer must be transparent and timely.
Any critical situation, misunderstanding or incomprehension, with clients or within the Firm, must be immediately reported to the reference Partner by those involved.
6. RELATIONS OF THE FIRM WITH SUPPLIERS AND THE PUBLIC ADMINISTRATION
Relations with suppliers are governed by common principles and are subject to constant monitoring by the Firm.
The choice of supplier must be oriented towards highest quality, taking into account the available resources and concrete needs.
The relationship with the public administration is conducted according to law provisions and in a transparent, official and documentable manner, avoiding or minimizing informal contacts.
Any form of gift that can be interpreted as exceeding normal commercial or courtesy practices, or in any case aimed at acquiring preferential treatment, is not allowed.
7. DISCLOSURE DUTIES
Anyone working for the Firm is required to notify to the reference Partner and the Managing Partners the existence of criminal proceedings against him/her, in order to safeguard the reputation and image of the Firm.
Anyone working for the Firm is required to notify to the reference Partner and the Managing Partners the existence of a complaint made by a client, the existence of legal proceedings against him/her brought by a client for professional liability and the existence of disciplinary proceedings against him/her relating to non-compliance with ethical regulations.
The Partners treat the information received with the utmost confidentiality and adopt the decisions that, according to the specific case, are suitable for the protection of the reputation and image of the Firm, together with the reasons, rights, prerogatives and interests of the person involved.
8. SOCIAL ENGAGEMENT AND NON-PROFIT ACTIVITIES
Compatibly with the available resources, the Firm makes at least one donation per year, for the benefit of non-profit organizations, charities or third sector entities engaged in social or environmental protection.
9. MONITORING AND IMPLEMENTATION
The Partners appoint an evaluation committee ("Comitato di Valutazione") with the following tasks:
- supervise the correct implementation of the Code of Ethics;
- take care of the Code of Ethics' updating;
- register and organize all internal procedures and take care of their updating;
- report to Partners any violation of the Code of Ethics.
The Partners have the task of ensuring the independence and autonomy of the Evaluation Committee with regard to the tasks assigned to it by the Code of Ethics.
Upon proposal of the Evaluation Committee, the Partners:
- sanction actions contrary to the Code of Ethics according to criteria of reasonableness, fairness, proportionality and effectiveness;
- approve the procedures indicated in the Code of Ethics as well as their updating;
- may establish methods for reporting violations of the Code of Ethics both from within and from outside the Firm.
10. CIRCULATION
The Firm distributes a copy of the Code of Ethics to all its employees, collaborators and professionals, publishes it on the Firm's website and indicates it in contracts, agreements and other documents with customers and suppliers as an integral and substantial part of the latter