1   Introduction

1.1         Code of Ethics

1.2         Values

2   Values System

2.1         Liability and compliance with laws

2.2         Honesty

2.3         Information transparency and completeness in company and accounting management

2.4         Fairness in company and resource management

2.5         Information confidentiality

2.6         Value of human resources and respect for the individual

2.7         Fairness in relations with Public Bodies and Institutions

2.8         Health and safety




  1. Introduction
  • Code of Ethics

This Code of Ethics expresses the principles and rules of conduct that Alfa Sistemi commits to in the management of its business activities. It describes the commitments and ethical responsibilities assumed by Alfa Sistemi towards Employees, Shareholders, Directors, Suppliers, Public Administration, Customers, the Community and, in a broader sense, any subject that is directly and/or indirectly involved in the activities of the company. The aforementioned are collectively defined as stakeholders, since they all have an interest in the business.
Alfa Sistemi recognises the importance of ethical and social responsibility and environmental protection in the conduct of its business and, to this end, promotes management directed at balancing the legitimate interests of its stakeholders.

The Code of Ethics is issued by the Board of Directors and approved by the Chair.


  • Values

Alfa Sistemi aims to conduct its activities in full respect of the following key values or principles:

  • Compliance with laws
  • Honesty
  • Information transparency and completeness in company and accounting management
  • Fairness in company and resource management
  • Information confidentiality
  • Value of human resources and respect for the individual
  • Fairness in relations with local authorities and public institutions
  • Protection of the environment, safety and sustainable development

All employees and collaborators must comply with and adhere to Alfa Sistemi’s values, and are required to observe these values with reference to the Organisation and all those who in various ways enable it to operate (Customers, Suppliers, Institutions, etc.).
Their abilities, knowledge and experience must be made available to everyone in order to achieve common objectives.
Objectives must be pursued and achieved guaranteeing the satisfaction of all, in particular Customers, Employees, Collaborators and Shareholders.
Access to equal opportunities is guaranteed to employees and collaborators in consistent accordance with legislation and internal regulations or policies.


  • Recipients and scope of application of the Code of Ethics

The following are the recipients of the Code of Ethics: Shareholders, Directors, Employees, Collaborators, as well as all individuals who, directly or indirectly, permanently or temporarily, enter into relationships or relations with Alfa Sistemi and who may, by means of their conduct and actions, have an impact on the objects and values of the Organisation.
Alfa Sistemi promotes dissemination of the Code of Ethics to all interested parties and the correct interpretation of its contents.

Alfa Sistemi adopts procedures to verify and monitor application of the Code of Ethics.


  1. Values System
  • Liability and compliance with laws

The regulatory framework which Alfa Sistemi refers to in the conducting of its business activities includes:

  • Current tax legislation;
  • Italian legislation on antitrust and competition;
  • Italian legislation on anti-corruption;
  • Laws, rules and regulations governing the purchase of goods and services by any public entity;
  • Italian Legislative Decree 231/01, as amended (administrative liability of companies and entities);
  • Italian Legislative Decree 81/2008, as amended (Consolidated law on occupational safety);
  • Italian Legislative Decree 152/2006, as amended (Consolidated law on the environment);
  • EU Regulation 2016/679 (GDPR);
  • Legislation on the safeguarding and protection of copyright (Italian Law 633 of 1941);
  • Administrative rules relating to personnel management;
  • Rules relating to the general occupational obligations;
  • Italian national collective bargaining employment contract (contratto collettivo nazionale di lavoro – CCNL);
  • Articles of association and regulations approved by the General Meeting of shareholders.

Alfa Sistemi’s primary value is compliance with current and applicable legislation. It requires that its Shareholders, Directors, Employees and Collaborators in general and anyone who represents Alfa Sistemi in any capacity, including in a de facto capacity, comply with legislation and all applicable regulations, as well as with the principles and procedures established for this purpose, and adopt an ethically correct conduct so as not to compromise their moral and professional reliability.


  • Honesty

Honesty is the fundamental principle guiding all of Alfa Sistemi’s business activities.

Initiatives, reports and communications are managed in accordance with said principle, which constitutes an essential element of organisational management.

Relations with stakeholders at all levels must be based on criteria and conduct that promote fairness, collaboration, loyalty and mutual respect.


  • Information transparency and completeness in company and accounting management

Alfa Sistemi recognises the fundamental value of correctly informing Shareholders, corporate governance bodies and competent departments regarding significant company and accounts-management events, and in no way justifies any action by its own collaborators that prevents control by the relevant bodies or organisations.

Alfa Sistemi ensures that the information flow between corporate governance bodies, the various company areas, management, the various top positions, the Supervisory Body and, where necessary, towards public authorities is constant and comprehensive. In any event, all information transmitted to the outside and circulating within the Organisation itself conform with the requirements of truthfulness, completeness and accuracy, including in relation to economic, financial and accounting data.


  • Fairness in company and resource management

Alfa Sistemi pursues its company objects in accordance with the law, its articles of association and company regulations, ensuring the correct functioning of its corporate governance bodies and protection of the proprietary and participatory rights of its Shareholders, safeguarding the integrity of the share capital and assets.


  • Information confidentiality

Alfa Sistemi guarantees the confidentiality of the information in its possession and compliance with current legislation concerning the processing of personal data.

All information available to the Organisation is processed respecting the confidentiality and privacy of the data subjects. Personnel in possession of information of interest to the Organisation or in relation to any stakeholder is in no way authorised to disclose or use any such information outside of the operational purposes for which it was authorised by company management.


  • Value of human resources and respect for the individual

Alfa Sistemi promotes respect for the individual, in addition to the physical and cultural integrity of the same.

The recipients of the Code of Ethics must act in a manner that respects the rights and dignity of others, while encouraging orderly coexistence in the workplace.

Human resources are considered essential to Alfa Sistemi’s development and, by virtue of this, it ensures professional growth and development of its personnel in order to increase the wealth of knowledge possessed in accordance with current legislation on the rights of the person and workers.

The Organisation guarantees working conditions that respect individual dignity and safe working environments. It applies current legislation and employment contracts with reference to its employees.


  • Fairness in relations with Public Bodies and Institutions

One of Alfa Sistemi’s goals is to manage relations, including contractual relationships, with Public Institutions, Bodies and Public Administrations in general with the utmost integrity and fairness.


  • Health and safety

Alfa Sistemi complies with all applicable rules, regulations and techniques concerning occupational health and safety, and adopts suitable management systems for this purpose.