Code of Ethics
SUMMARY
1 General provisions
2 Relations with third parties
2.2 Relations with suppliers, contractors, business and financial partners
2.7 Relations with persons called upon to make statements before judicial authorities
3 Transparency and self-monitoring
4 Staff policies
5 Health, safety and environment
6 Privacy of personal and corporate data
7 Protection of corporate assets and use of IT systems
8 Code violation and penalties
Alilaguna S.p.A. adopts the Organization, Management and Control Model pursuant to Legislative Decree 231/2001.
Presentation
Alilaguna is in charge of organizing and managing the public transport service between Marco Polo Airport in Tessera, Murano, Lido, the historic center of Venice, Giudecca Island and the Cruise Terminal: to this end, it has signed a service contract with the entrusting body Municipality of Venice in accordance with current regulations. In addition to this it organizes and manages services of a commercial nature.
In these areas it operates with the aim of achieving maximum customer satisfaction and is aware that Quality, Health and Safety and Environmental protection are fundamental strategic factors on which to base business development and efficiency.
Alilaguna also considers it essential to carry out its activities in compliance with the law, within a framework of fair competition, with fairness, integrity, transparency, legitimacy and clarity, respecting the interests of customers, employees, shareholders, business and financial partners and the community with which it relates.
This Code of Ethics therefore regulates the set of rights, duties and responsibilities that Alilaguna adopts in its relations with all the interlocutors with whom it interacts within the scope of its activity. Consequently, the set of ethical principles and values expressed in the Code of Ethics must inspire the activities of all those who work on behalf of Alilaguna in pursuit of the Company's purposes.
Alilaguna has provided itself with this Code of Ethics (hereinafter also “Code”) as an ethical-behavioral guideline tool with the purpose also of defining reference values, corporate commitments and principles inspiring behavior oriented toward the prevention of crimes pursuant to Legislative Decree 231/2001.
This Code does not replace external and internal laws and regulations, but constitutes a supplementary document that promotes their application within the company.
This Code is to be understood as an essential and integral part of the Organization, Management and Control Model of Alilaguna in accordance with Article 6 of Legislative Decree 231/2001, being a tool of the preventive system prepared by the model itself.
Finally, the Code is consistent with all the organizational tools adopted and to be adopted in the future by Alilaguna. Cited in this regard are:
the “Service Charter” available on the company website at https://www.alilaguna.it/node/752,
the Internal Regulations of Alilaguna,
the ISO:9001 Quality system,
the Safety system adopted in accordance with the Confindustria Veneto/INAIL Veneto Memorandum of Understanding.
1.1 General Principles
Compliance with the principles of the Code is of fundamental importance for the smooth running of Alilaguna's management. To promote its full application, Alilaguna is committed as follows:
enforce in all relationships, the laws in force in the context in which it operates;
provide quality services, based on professionalism, experience, attention to users and innovation;
prohibit any unlawful and otherwise improper act towards employees and collaborators, suppliers, passengers and customers, the community and public authorities;
adopt organizational tools aimed at compliance with the principles of legality, transparency, fairness and loyalty and to monitor compliance with these tools and their updating;
promote the value of human resources, helping to increase the wealth of skills possessed by each employee;
promote respect for the physical, moral and cultural integrity of the person, guaranteeing individual dignity and safe working environments, prohibiting any form of psychological, physical and moral harassment of employees, external collaborators, suppliers, passengers and customers;
prohibit corrupt practices, fraud, fraud, illegitimate favors, collusive behavior, solicitations, direct and indirect, for the achievement of benefits or in the interest of the company.
Alilaguna guarantees, also through the possible identification of specific internal functions:
the maximum dissemination of the Code among the Recipients of the Code, as defined below;
the updating of the Code;
the performance of verifications with regard to reports of violations of the rules of the Code;
the evaluation of the facts reported and the consequent implementation, in the event of ascertained violation, of appropriate sanctioning measures;
the protection of anyone who has to provide reports of possible violations of the Code or the rules referred to above.
1.2 Recipients, scopes of application and obligations
Recipients of the Code are the corporate units, managers and employees, collaborators and all those who, directly or indirectly, permanently or temporarily, establish with Alilaguna, in any capacity, relationships and collaborative relations aimed at achieving the objectives of Alilaguna.
Alilaguna is committed to maintaining with everyone, a relationship with connotations of honesty, fairness, integrity, transparency, legitimacy, clarity and mutual respect.
Recipients of this Code, in the context of their relationships with Alilaguna and third parties, must adopt principles of honesty, fairness, integrity, transparency, legitimacy, clarity and mutual respect and, also, must be available to the verification of the above, according to current regulations and internal procedures of the Company.
Each Recipient is asked to be familiar with the Code and the reference standards governing the activity carried out within the scope of his or her function.
Alilaguna's employees, in addition to observing principles of loyalty and fairness in the execution of the employment contract according to good faith, must refrain from carrying out activities in competition with Alilaguna, respect the company rules and abide by the precepts of the Code, compliance with which is also required pursuant to and for the purposes of Article 2104 of the Civil Code.
Alilaguna employees are specifically obliged to refrain from conduct contrary to the rules of the Code, to demand compliance with them and to refer to their superiors or the functions delegated to them, if they need clarification on how they are applied.
1.3 Specific Obligations of Directors, Managers and Heads of Business Units or Functions
Each Director, Manager and Head of Business Units or Functions has the obligation to:
set an example for his or her co-workers by his or her own behavior;
promote compliance with the rules of the Code by the Recipients;
work to ensure that the Recipients comply with the Code from the point of view of the quality of work performance within the scope of their activities.
1.4 Adoption, implementation and control of the Code
The Code is adopted by Alilaguna by resolution of the administrative body. The Code may be revised and supplemented, also on the basis of suggestions and proposals that may be made by anyone.
Alilaguna undertakes, also through the identification of appropriate structures, bodies or functions, in compliance with current regulations, to carry out the following:
establish criteria and systems aimed at reducing the risk of violation of the Code;
prepare information and training programs for the Recipients, aimed at the best implementation of the Code;
carry out activities to control the adequacy of the Code and adopt the necessary measures to adapt the Code.
2 Relations with third parties
2.1 Passengers Relations
Alilaguna aims to achieve excellence in the services it offers, taking into account the needs of passengers and striving to meet their demands. Alilaguna's goal is to ensure an immediate, qualified and competent response to their needs, imprinting its behavior on fairness, courtesy and cooperation.
In particular, Alilaguna is committed as follows:
observe and enforce the internal procedures for the management of relations with passengers;
comply with all applicable legal and regulatory provisions;
provide accurate and comprehensive information about the services provided, so that the passenger can make informed decisions;
ensure services geared to maximum customer satisfaction, respecting health and safety, environmental protection and privacy.
2.2 Relations with suppliers, contractors, business and financial partners
In contracting, procurement and, in general, in the supply of goods and/or services, the Recipients, to the extent of their competence, for the management of relations with suppliers, contractors, business and financial partners, must observe the following rules:
comply with internal and legal procedures;
not preclude any supplier company in possession of the necessary prerequisites, the possibility of presenting to Alilaguna its offer of goods and services,
adopt objective evaluation criteria of the offers according to declared and transparent methods;
maintain loyal and collaborative relations, in line with good business practices.
Alilaguna prohibits illicit activities of purchasing, receiving, concealing and laundering goods, the use in illicit economic and financial activities of money, goods or other utilities from criminal activities in any form or manner.
The Company does not engage in business dealings with persons operating outside the law such as, but not limited to, persons connected with the environment of money laundering, drug trafficking and usury. Therefore, it is prohibited to receive or make handouts to individuals, companies or organizations even suspected of carrying out such activities.
In its relations with suppliers, contractors, and business and financial partners, Alilaguna adopts principles of transparency and fairness, checking available information in advance, including financial and reputational information; therefore, before establishing significant business relations with new economic operators, it ascertains their respectability, reliability, and legitimacy of their activities.
2.3 Relations with Public Institutions
Relations with Public Institutions are reserved exclusively for the functions and responsibilities delegated to them.
It is not permitted to offer money, gifts or other benefits to managers, officials or employees of the Public Institutions and public service appointees or their relatives and to the same through other private parties, unless they are gifts or utilities for use and of modest value.
Gifts and acts of courtesy and hospitality to public officials public employees and public service appointees with whom Alilaguna has business dealings are still permitted if they are such that they do not compromise the integrity or reputation of either party.
It is forbidden to use or present statements or documents that are false or attest to things that are not true, or to omit information in order to obtain contributions, financing, other disbursements or facilities, however denominated, granted by the State, a public body or the European Union.
It is prohibited to mislead anyone, through artifice or deception, in order to procure the Company an unfair profit to the detriment of others.
It is also forbidden to use contributions, financing or other disbursements however denominated, which may have been granted to Alilaguna by the State, a public body or the European Union, for purposes other than those for which the same have been assigned. It is also forbidden to:
to modify, in any way, the operation of a computer or telematic system of the public administration;
access without right to data, information or software contained in computer or telematic systems of the public administration;
exceed the limits of any authorizations granted in accessing such data or programs pertaining to the public administration;
access without right to computer or telematic systems used in the management of public order, public security, health, civil protection or, in any case, of general public interest
committing acts aimed at destroying, deteriorating, deleting, altering or suppressing information, data or computer programs used by the State or other public entity or pertaining to them or, in any case, of public utility;
committing acts aimed at destroying, damaging, rendering wholly or partially unserviceable computer systems of public utility or seriously hindering their operation
operate any form of alteration or falsification of statements and communications sent to the public administration, including by electronic means;
pressure public employees to alter data or information in public archives for the benefit or interest of the Company.
2.4 Relations with Political and Trade Union Organizations
Alilaguna maintains relations with trade unions and other political, opinion and similar associations, in compliance with the regulations in force, this Code, and the bylaws, adopting principles of fairness and impartiality.
Alilaguna does not make contributions to political and trade union parties, movements, committees and organizations, their representatives and candidates.
2.5 Relationship with the public information system
Outward information must be truthful, proportional and transparent.
Alilaguna therefore carries out communications in the public domain that are accurate and consistent with respect to the various recipients.
Relations with the mass media are reserved exclusively for the corporate functions and responsibilities delegated to them.
Recipients may not provide information in the name and on behalf of the Company to representatives of the public information system, nor undertake to provide it, without the authorization of the relevant functions.
Alilaguna carries out external communications and advertising messages with content that respects the laws and dignity of others.
2.6 Relationships with operators in the market
Alilaguna is committed to complying with legal regulations on competition and adopts fair behavior with all operators in the market.
Alilaguna prohibits:
any behavior toward other operators in the sector, which could integrate any illicit or unfair form of impropriety or unfairness, in any case capable of creating distorting effects on competition;
any activity of installation, downloading and use through the company's equipment, of protected and unauthorized software, programs and databases, with injury to the rights of third parties.
Alilaguna carries out the development of new services in compliance with all applicable national and international regulations, especially the regulations provided for the protection of other people's intellectual or industrial property.
2.7 Relations with persons required to make statements before judicial authorities
Alilaguna cooperates with judicial authorities, law enforcement agencies and any public official in the context of inspections, audits, investigations or judicial proceedings.
Alilaguna recognizes the value of the procedural originality of those who must make statements to judicial authorities.
Therefore, any company manager who has dealings with judicial authorities and public officials must avoid any behavior tending to omit relevant statements or to make false statements or, finally, to evade investigations.
3 Transparency and Self-Control
Alilaguna is committed to promoting the development of organizational culture on the assumption that the conduct of its management must be transparent and therefore characterized by an effective internal system of controls.
This system of controls, consisting of a set of tools aimed at ensuring compliance with laws, regulations and company procedures, must be hinged not only on mechanisms of a regulatory nature, but also on mechanisms of self-regulation within which each Recipient, in relation to his or her function, plays a role of conscious activation.
4.1 Staff Selection
Human resources are a fundamental resource for continuity and development of Alilaguna and represent decisive conditions for achieving the company's objectives.
Alilaguna is committed to developing the abilities and skills of each employee and expects employees, at every level, to cooperate in maintaining a climate of mutual respect for the dignity, honor and reputation of each person in the company.
The evaluation of staff to be hired is carried out on the basis of matching the candidate's profiles to the company's needs, while respecting equal opportunity.
The information collected is strictly related to the verification of the possession of the professional and psycho-aptitude requirements for the job, while respecting the privacy and opinions of the candidate. Alilaguna does not discriminate on grounds of race, ethnicity, nationality, sex and religion and therefore respects the rights of each candidate in compliance with Art. 3, L. 13/10/1975, n. 654 .
In the case of employment of non-EU foreign workers, the existence of a valid residence permit pursuant to Article 22 of Legislative Decree 286/98 must be verified. The term employment should be interpreted in a broad sense; therefore, the case of employment should also be referred to administered workers pursuant to Legislative Decree 276/2003 : Alilaguna also verifies the existence of valid residence permit of these workers.
Finally, although the Entity's administrative liability for the crime of employment of irregular workers by subcontractors is not expressly configurable, pursuant to Legislative Decree no. 231/01, also to be borne by the contractor, taking into account that the law provides for joint and several liability for contracts, whereby the contractor is jointly and severally liable with the subcontractor for both wages and social security and insurance contributions (excluding the obligation for civil penalties for which only the person responsible for compliance is liable), Alilaguna carries out checks on the regularity of labor relations in place with subcontractors and their workers employed by Alilaguna.
4.2 Harassment in the workplace
Alilaguna requires that in its sphere of activity no cases of harassment, not even potential, take place.
Therefore, Alilaguna prevents mobbing and personal harassment activities of any kind, including sexual harassment, by prohibiting any behavior detrimental to a person's dignity.
4.3 Alcoholic Substances, Narcotics and Pornographic Material
Alilaguna requires each employee to personally contribute to maintaining the work environment respectful of the sensitivities and safety of others, including passengers.
Alilaguna therefore prohibits the consumption of alcoholic substances, narcotics or substances of similar effect, in the work environment; it is also absolutely forbidden to perform work under the influence of such substances.
It is forbidden to use company facilities to promote, in any way, the circulation of narcotic substances and pornographic materials and to possess such substances and materials on Alilaguna's premises or in any place that, in any case, can be traced back to Alilaguna's organizational sphere.
4.4 Smoking
Employees are required to comply with and enforce current legal provisions and company regulations regarding the prohibition of smoking.
5 Health, Safety and Environment
5.1 Health, Safety and Environment Policy
Alilaguna, as part of its activities, is committed to spreading and consolidating a culture of health and safety, developing risk awareness and using all necessary resources to ensure the health and safety of employees, collaborators, passengers and third parties.
Alilaguna's staff, within the scope of their duties, must participate in risk prevention, health and safety protection towards themselves, collaborators, passengers and third parties.
Alilaguna develops its activities with the awareness that the achievement of its objectives must be compatible with the protection of the environment and respectful of the relevant legal and regulatory provisions.
Alilaguna's staff, within the scope of their duties, must contribute to safeguarding the environment, in compliance with legal and regulatory provisions and company procedures. All employees and collaborators, especially those who are in charge of navigation activities, are obliged to observe the regulations concerning the discharge of waste and toxic-harmful materials and, likewise, the regulations concerning related administrative processing.
5.2 Obligations of Recipients
Recipients, within the scope of their duties and functions, participate in the process of risk prevention, environmental protection, and health and safety protection with respect to themselves, co-workers, passengers, and third parties.
Every worker must take care of:
of his own health and safety and that of other people in the workplace, on whom the effects of his actions or omissions fall, in accordance with his training, instructions and means provided by company management,
of respect for the environment, in accordance with his training, instructions and means provided by company management.
Alilaguna plans information and training interventions on health, safety and environmental protection, and employees and collaborators adhere to the process of risk prevention on health and safety and environmental protection, including through participation in these interventions.
A sense of responsibility and behavior related to the management of occupational health and safety and environmental protection is an integral part of each employee's job description.
6 Privacy of personal and corporate data
6.1 Principles
Alilaguna complies with the requirements on the confidentiality of personal data set forth in Legislative Decree 196/2003 - “Code on the protection of personal data” and EU Reg. 2016/679 - GDPR.
Alilaguna's activities also involve the acquisition, storage, processing, communication and possible dissemination of data, news, documents and other information pertaining to services, administrative procedures, financial operations, contracts, deeds, reports, notes, studies, drawings, photographs, software, etc.
Alilaguna's databases may contain:
personal data protected by legislation protecting privacy;
data that by negotiated agreement cannot be disclosed externally, the inappropriate or untimely disclosure of which could produce damage to the Company.
It is the obligation of every employee and collaborator to ensure the confidentiality of all data and information acquired in connection with their work function.
Information, knowledge and data acquired or processed by employees and collaborators in the course of their work belongs to Alilaguna and may not be used, communicated or disclosed without reason and specific authorization from the superior or the competent function.
Alilaguna is committed to protecting information related to its employees and third parties, generated or acquired within and in business relationships, avoiding any misuse of the same.
With particular regard to the processing of workers' personal data, Alilaguna implements specific precautions aimed
at informing each manager, employee or external collaborator about the nature of the personal data subject to processing
by the Company, the methods of processing and the areas of communication and dissemination.
6.2 Obligations of Recipients
Without prejudice to the prohibition of disclosing information, knowledge and management data or making use of them in a way that causes harm or damage to the Company, each Recipient must:
acquire and process only the data strictly necessary for the performance of his or her functions and functional to the Company's needs;
acquire and process the data themselves only within specific procedures;
store the data themselves in such a way as to prevent unauthorized others from gaining knowledge of them;
disclose the data themselves within preestablished procedures and/or upon explicit authorization of the superior positions and/or competent functions and in any case, after having ascertained their disclosability
ensure that there are no absolute or relative constraints on the disclosability of information regarding third parties connected to Alilaguna by a relationship of any nature and, where appropriate, obtain their consent;
process the data in such a way that any person authorized to have access to it can easily draw as accurate, exhaustive and truthful a picture of it as possible.
7 Protection of company assets and use of IT systems
7.1 Protection of Company Assets
Alilaguna's employees and collaborators are responsible for the protection of the Company's assets entrusted to them and must use them in a manner consistent with the Company's instructions to them. Employees and collaborators have a duty to promptly inform their direct supervisors of events potentially harmful to the Company, concerning, by way of example, theft, loss, malfunction.
It is forbidden to misuse Alilaguna's property and resources or allow others to do so.
7.2 Use of computer systems
All employees and collaborators of Alilaguna are obliged to use the set of computer and telematic tools made available to them for the performance of their work solely for productive purposes. It is forbidden to use them for other purposes and, in particular, for illegal purposes.
In any case, computer and telematic systems must be used in accordance with current legislation, company regulations and procedures, specifically, but not exclusively, regarding privacy, copyright, computer fraud and abusive access to computer systems.
System administrators and users of information technology tools must adhere to principles of diligence and fairness, including for the purpose of verifying and ensuring the efficient and optimal functionality of the same.
8 Violation of the Code and Sanctions
8.1 Sanctions
Sanctions for non-compliance by employees and corporate bodies
Compliance with the rules of this Code must be considered an essential part of employees' contractual obligations pursuant to and in accordance with Article 2104 of the Civil Code. Violation of the rules of the Code, harming the relationship of trust between the employee and the employer, may constitute a breach of the primary obligations of the employment relationship or a disciplinary offence, in compliance with the procedures provided for in Article 7 of the Workers' Statute, with all legal consequences, including with regard to the preservation of the employment relationship, without prejudice, however, to compensation for damages arising therefrom.
The imposition of sanctions is the responsibility of the Administrative Body.
If the conduct in violation of the principles of this Code is referable to the General Manager or to the Administrative Body, the report must be addressed to the control body (Board of Auditors), which will inform the Administrative Body if the subject of investigation is the conduct of the General Manager, or the Shareholders' Meeting of the company if the subject of investigation is the conduct of the members of the Administrative Body, leaving the offices receiving the report with the burden of taking the relevant measures.
In any case, maximum protection must be guaranteed to the person who will have made a report of violation of the Code of Ethics.
Sanctions for non-compliance by collaborators and other third parties
Compliance with the Code must be considered an essential part of the contractual obligations assumed by collaborators and/or parties having business relations with the company. Violation of the rules of the Code may constitute breach of contractual obligations, with all legal consequences, including with regard to the termination of the contract and/or assignment, and may result in compensation for damages arising therefrom, the company undertaking to include such a clause in the relevant contracts.
To the extent necessary, in case of violation of the Code, the disciplinary system provided for in the Manual - General Part of the Management, Organization and Control Model ex Legislative Decree 231/2001 will be applied.
The Code of Ethics is brought to the attention of the Recipients and the public through appropriate communication and dissemination activities, including through the Company's website. In order to ensure the correct understanding of the Code to all managers, employees and external collaborators of the Company, the Supervisory Board promotes, in agreement with the internal organizational structures, information plans aimed at fostering awareness of it.
