our values, our principles, our commitments
ClarineT Shareholders believe in the importance of clearly defining the values and principles that guide ClarineT's activities - both within and outside the Company - so as to ensure that all Company activities are conducted in compliance with applicable regulations, in a context of fair competition, honesty, integrity and good faith, and in conformity with the legitimate interests of all stakeholders with whom ClarineT interacts on a daily basis: shareholders, employees, suppliers, customers, commercial and financial partners, local communities and institutions of the countries in which ClarineT and ClarineT Group companies operate.
Code of Ethics
These values are set forth in the ClarineT Code of Ethics, approved by the Shareholders on 27 May 2015 and enforced by our CEO.
Everyone working for ClarineT - from the members of Company bodies and top management downwards - is called upon these principles, and to ensure that they are observed, in the context of their own functions and duties. The Code represents an essential general principle of Model 231, the synergies between the Code of Ethics and the Model are underlined by the assignment - established by Model 231 - of the function of Guarantor of the Code of Ethics, with the duty of promoting and verifying its implementation.
The Code of Ethics applies to all direct or indirect subsidiaries, both in Italy and abroad. Subsidiaries adopt the Code of Ethics and adjust it - where necessary - to their specific characteristics, in accordance with their own managerial independence. Each subsidiary assigns the function of Guarantor of the Code of Ethics to its own watch structure.
ClarineT’s representatives within the company bodies of other affiliates, consortia and joint ventures promote the principles and contents of the Code within their respective areas of responsibility.
The Code of Ethics is available in the Italian original. Translation in foreign languages, in order to ensure its maximum dissemination in the international context in which ClarineT operates is undergoing.
The widespread distribution of the Code of Ethics has been continued, from the Shareholders and Top Management down to newly-hired employees, through a range of initiatives using interactive tools, dedicated presentations and integration into the Company's institutional training courses.
Stakeholders can contacts the Guarantor of the Code of Ethics either to propose improvements or to highlight potential infringements to the email odv@clari-net.it.
Model 231
With regard to this issue, the Shareholders of ClarineT – in their meeting of 27 May 2015 – approved an organisational, managerial and control model pursuant to Legislative Decree no. 231 of 2001 (henceforth "Model 231") and created the associated Watch Structure.
The Watch Structure monitors the effectiveness and adequacy of Model 231 and reports to the CEO on its implementation, approves the annual program of supervisory activities and communicates the outcomes of activities implemented during the year in relation to assigned tasks.
In order to ensure the effectiveness of the control process, information flows are provided towards the Watch Structure and from the Watch Structure towards upper management.
In the Model 231 of ClarineT are defined the control measures (general standards of transparency of the activities and specific control standards) to prevent the offences set out in Legislative Decree No. 231 of 2001 and, in accordance with the law, is established a disciplinary system to punish any possible violation of the Model 231.
Stakeholders can contacts the Watch Structure either to propose improvements or to highlight potential infringements to the email odv@clari-net.it.
The Model 231 is available in the Italian original. Translation in foreign languages, in order to ensure its maximum dissemination in the international context in which ClarineT operates is undergoing.
WHISTLEBLOWING
ClarineT (Company) aware of the importance of activating adequate reporting channels in order to protect the integrity of the company and guarantee compliance with the principles of legality, fairness and transparency, also towards third parties, in the exercise of ClarineT activities, has activated specific company reporting channels in compliance with the Italian Legislative Decree no. 24/2023 (transposition of the European Directive 2019/1937 on Whistleblowing). To access the service please follow the link below:
Downloads
Here you can find a copy of our Code of Ethics and this is the current Model 231.
A preset module for communications to Supervisory Body Legislative Decree 231 (Organismo di Vigilanza) available here (modulo segnalazione OdV).
WHISTLEBLOWING DISCLAIMER
WHO CAN MAKE THE REPORT
People who operate in the corporate working context as
• employed persons;
• self employed workers and collaborators working for the Company;
• freelancers and consultants working for the Company;
• volunteers and trainees , paid and unpaid, who work for the Company;
• shareholders and persons with administrative, managerial, supervisory or representative
functions , even if these functions are performed merely de facto at the Company,
even when the legal relationship has not yet begun , if the information on infringements was acquired during the selection process or at other pre contractual stages or during the probationary period or after the termination of the legal relationship if the information on the infringements was acquired during the relationship itself.
WHAT BEHAVIOURS MAY BE REPORTED
Relevant Reports are constituted by reports concerning behaviours, acts or omissions which harm the public interest or the integrity of the Company of which the whistleblower has become aware in the working context and which consist of
• offences that fall within the scope of application of European Union acts relating to the following sectors : public contracts, financial services, products and markets and prevention of money laundering and terrorist financing; product security and conformity ; transport safety; environmental protection; public health; consumer protection; privacy and data protection ; security of networks and security of information systems
• acts or omissions that harm the financial interests of the European Union , such as fraud, corruption and any other illegal activity related to Union expenditure;
• acts or omissions relating to the internal market, including infringements of EU competition and state aid rules as well as corporate tax, free movement of goods, persons, services and capital.