Ethics

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our values, our principles, our committments

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.

 

Downloads

Here you can find a copy of our Code of Ethics and this is the current Model 231.