INDEX

Premise

Mission and Vision of Vitamina C

Ethical Principles: overview 

Ethical principles: detail

Transitional and final provisions

 

PREMISE

Vitamina C (hereinafter also just the Agency), founded in Turin in 2003, is a sole proprietorship, owned by Claudia Vianino, who deals with communication, public relations and press office in favor of clients, individuals, organizations and brands that operate or want to operate in the world of sports and in particular outdoor sports, such as cycling, running, skiing and mountain sports, as well as in the travel, camping, fitness fields and other sectors related with outdoor activities.

 

The offer of the Agency's products and services includes three macro-sections: press office (relations with the media, online and offline, both traditional and new media), copywriting (drafting of content for communication purposes in a broad sense, advertising journalism, web writing etc), social media management (management of the social communication of the Agency's clients). The activity can also extend to events (planning, implementation, coordination) and marketing consultancy and strategic communication (drafting of communication plans with actions and interventions in the short and long term).

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The Agency has the important task of communicating companies, institutions, individuals who rely on it, effectively, efficiently and promptly. Truth, transparency, clarity, conciseness, correctness guide every action of the Agency, avoiding deception and manipulation of the information entrusted to it.

 

Vitamina C is aware that the adoption of a Code of Ethics is of primary importance for the performance of one's work and it has decided to clearly establish the set of corporate values that inspire the Agency.

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MISSION: VISION OF VITAMINA C

The principles enshrined in this Code of Ethics are binding and must be observed by all Recipients and, in any case, by all those who, within the Agency, perform functions of representation, administration or management, or who exercise, even in fact, the management and control, by all employees, without exception, by those who cooperate and collaborate with it - in any capacity - in the pursuit of the corporate Mission and for anyone who has business relationships with it (for example, suppliers, consultants, business partners, etc.).

 

Vitamina C undertakes to release this Code of Ethics as widely as possible, so that it is brought to the attention of all Recipients, as well as to ensure adequate training on its contents.

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The Agency undertakes to faithfully observe the provisions of this Code of Ethics and to carry out its activities with the utmost diligence, professionalism and reliability, constantly promoting correct and decent behavior in relations with customers, suppliers and partners and protecting the reputation and Vitamin C image as well as generating ethical, economic, social value and building long-term economic and environmental value.

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The Vision of the Agency, which works in the world of sports and outdoor activities, is to be proactive, timely and energetic, as is its pay-off “the communication energizer”.

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ETHICAL PRINCIPLES: OVERVIEW

• Compliance with the regulatory provisions applicable in Italy and in any other country in which the Recipients operate

• Transparency towards all stakeholders, i.e. all individuals, groups of individuals or institutions whose interests are directly or indirectly influenced by the performance of company activities (eg, Customers, employees , collaborators, suppliers, investors, Public Administration, etc.)

• Responsibility towards the community which, even indirectly, can be influenced in its economic and social development by the activities of the Agency

• Protection of safety and health, physical and moral integrity as well as the rights of employees and collaborators whose professional skills it undertakes to enhance

• Protection and safeguarding of the environment in all its components

• Refusal of behaviors which, although aimed at achieving a result consistent with the interest of the Agency, present aspects that are not compatible with the principles set out in this Code of Ethics and with Vitamina C's commitment to comply with the applicable regulatory provisions, as well as the behavioral and procedural rules adopted.

​The Recipients conform their conduct to the aforementioned Principles as set out in the following paragraphs of this Code of Ethics. Under no circumstances can the conviction of acting in the interest or to the advantage of the Agency justify conduct contrary to them.
 

Furthermore, the Recipients of the Code of Ethics undertake to:

• Respect local customs and traditions by protecting and preserving "diversity" and stemming all forms of discrimination

• Support, respect and guarantee the freedom of assembly, information, speech, criticism and news, the freedom of the media, comparable to the clients of the Agency as essential for the practice of PR and communication.

• Promote truthful and fact-based communication

• Promote compliance with the laws on privacy and data protection as better regulated in the specific Vitamina C policy

• Avoid situations, even potential conflicts of interest

• Ensure high standards of performance, professionalism and ethics in communication, also thanks to training and research courses

• Act in compliance with competitors and customers, avoiding unfair competition

• Maintain harmless and strengthen the reputation of the Agency itself, of the people who work or collaborate with it, as well as of the customers themselves by refusing to adhere to PR campaigns contrary to the values of Vitamin C, to public order, to morals.

• Respect copyright and intellectual property in general

• Respect and protect consumers, complying with current legislation on the subject (Consumer Code), avoiding misleading or deceptive messages

• Legality - All behaviors in the context of work activities carried out on behalf of or in the interest of Vitamin C are based on the most rigorous compliance with the national, EU and international laws in force and applicable to the Agency or in the management of relations with it.

• Prevention of corruption - The Agency promotes - and requires - compliance with the anti-corruption principles and regulations applicable to it. Corruption in all its forms is prohibited and full respect for the principles of integrity, fairness, impartiality, legality is promoted

• Prevention of conflict of interest - Recipients operate impartially in the exclusive interest of Vitamin C, taking decisions with responsibility, transparency and according to objective evaluation criteria, avoiding situations where they are, or may even appear, in conflict of interest . In the event of a conflict of interest, even if only potential, the Recipients inform the Owner of the Agency without delay

• Professionalism and reliability - Vitamina C carries out its business in accordance with the highest standards of ethical-professional behavior. The Recipients are called to carry out the activities of their competence with an adequate commitment to the responsibilities entrusted to them, protecting the reputation of the Agency and customers

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ETHICAL PRINCIPLES: DETAIL

 

•Unfair competition- The Agency believes in healthy and fair competition, as well as in a competitive market and acts in compliance with antitrust legislation. Vitamin C rejects collusive practices, obstructive behavior and the dissemination of false, misleading, distorted or disparaging information about a competitor or its services. Therefore, deceptive behaviors are prohibited. To this end, the Agency refrains from implementing acts that may integrate forms of unfair competition.

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•Confidentiality and protection of personal data- The agency protects the confidentiality of the information that constitutes corporate assets, or in any case of the information or personal data of third parties in its possession, in the most rigorous observance of the legislation in force also regarding the protection of personal data. The obligation of confidentiality therefore extends, in addition to corporate data that are not already public and to the management methods of corporate processes, also to information relating to customers, suppliers and commercial partners, of which the Agency acquires and processes the data. personal. No Recipient can benefit of any kind, direct or indirect, from the use of confidential information or personal data, acquired during the activities carried out for Vitamin C, nor communicate such information to others or recommend or induce others to use them. . In communicating information to third parties, where necessary or permitted for professional reasons, the confidential nature of the information must be expressly declared and compliance with the obligation of confidentiality of the third party required (Non Disclosure Agreement). In the case of access to password-protected electronic information, the latter can only be known by the assignees, who are obliged to keep it carefully and not to disclose it. Vitamin C in order to better protect these rights has adopted a Privacy Policy, made public on the Agency's website and delivered and signed by each of its employees and collaborators.

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•Value of the person and human resources- Human resources represent for Vitamin C a precious asset for the development and growth of the Agency, which protects the value of the human person and does not tolerate discriminatory, harassing and / or offensive conduct, based on age, sex, sexual orientation, race , color, language, nationality, political and trade union opinions, religious beliefs, marital and family status, disability, genetic information or other personal characteristics not relevant to work. In the selection and management of personnel, Vitamina C adopts criteria of equal opportunity, merit and enhancement of the abilities, skills and potential of individuals. The Agency supports gender equality and the full participation in equal measure of all people - regardless of gender and sex - in life and / or business choices, considering them essential elements for building an inclusive society.

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•Job security- Vitamin C promotes the health and safety at work of its employees and of all those who access their offices and work environments and is committed to ensuring working conditions that respect individual dignity, promoting a healthy lifestyle and a fair balance between private life and work. Work environments are always made safe and healthy, and equipped with air purification devices to eliminate mold, fungi, viruses and bacteria.

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•Protection of the environment and cultural heritage- In the management of company activities, Vitamina C takes utmost account of the protection of the environment and cultural heritage, pursuing the improvement of environmental conditions and the protection of the cultural and landscape assets of the community in which it operates, in full compliance with current legislation. In particular, the Agency is actively committed to reducing the impact on the environment with its work, promoting, among other things, actions aimed at differentiating the collection, recycling and proper disposal of waste, minimizing the use of printers (equipped with recycled toner and cartridges), the consumption of paper (the one used by the Agency is recycled paper), and using pens obtained from the recycling of plastic materials.

The cartons and packaging are recycled as much as possible and - while respecting the correct decoration of the package - re-using them for sending the test samples to the various journalists.

In the toilets, only eco-natural type disposable toilet paper and wipes are used.

Each employee and collaborator receives a bottle as a gift every year, for proper daily hydration and above all, for reuse, at the expense of disposable bottles. Finally, the Agency favors in all possible ways the reduced consumption of energy.

 

•Fight against money laundering and self-laundering- Vitamin C requires maximum transparency in commercial operations and in relations with third parties, in full compliance with national and international regulations regarding the fight against money laundering. All financial transactions are adequately justified in contractual relationships and are carried out by means of payment that guarantee their traceability. Consequently, the Recipients cannot enter into business relationships on behalf of the Agency with partners, customers, suppliers or third parties who do not give guarantees of integrity, do not enjoy a good reputation or whose name is associated with events related to money laundering or, in general, to criminal activities of any kind.

 

•Gifts and donations- The Agency does not offer or accept gifts of any kind and size, aimed at obtaining advantages or favors of any kind; in particular, it does not offer or accept gifts during a commercial negotiation, a tender or the submission of an offer. Small gifts or courtesies, forms of hospitality or donations in kind may be allowed, only if authorized by the Owner of the Agency and duly documented. They must be such as not to be interpreted, in any way, as aimed at obtaining advantages and favors in an improper way.

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•Protection of company assets- Company assets must be used acting diligently, responsibly and in order to guarantee their protection and integrity. The use of company assets for personal needs or unrelated to service reasons must be previously authorized by the Agency Owner.

 

•Protection of industrial and intellectual property- Vitamin C ensures, in implementation of the principle of observance of the laws, compliance with internal, community and international regulations aimed at protecting industrial and intellectual property, guaranteeing the protection of trademarks, copyrights, trade secrets and own patents and third parties. In particular, it protects its extensive Media database, which represents the basis of the Agency's activity and must not be duplicated, sold, exported, given away, photographed or copied, not even in part. Furthermore, it is expressly forbidden to use the Agency's know-how or copyrights for purposes other than those established by the relevant agreements or regulations. Without the prior and specific authorization of the Data Controller, employees and collaborators of the Agency may not use the results obtained by the Agency for personal purposes, (including, for example, the publication of these results on websites, social networks, and the like), even if these were achieved thanks to the work of the employee or collaborator.

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•Use of IT equipment and systems- All users authorized to use the Agency's equipment and IT systems are required to comply with the regulatory provisions in force and may not engage in conduct that could damage, alter, deteriorate or destroy the IT or telematic systems, programs and IT data, from the Agency or from third parties; illegal access to IT systems, acquisition or transfer of access codes to protected IT or telematic systems are prohibited. It is forbidden to use company equipment and IT systems, for purposes contrary to the law, public order or morality, as well as to commit or induce the commission of crimes or in any case to racial hatred, the exaltation of violence , to discriminatory acts or to the violation of human rights.

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•Quality of services rendered- The Agency pays the utmost attention to the quality of the services rendered. The Recipients are therefore called upon to provide truthful, precise and exhaustive information about the quality and type of services to be rendered.

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•Transparency and correctness in the management of information- Vitamin C believes that the transparency of information represents an indispensable value, to which it conforms its work activity also for what concerns the keeping of its own accounts. In the management of the Agency's activities, the Recipients are required to make transparent, truthful, complete and accurate information, even externally, refraining from disseminating false information or carrying out simulated operations.

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•Relations with customers, suppliers, partners- Vitamin C aims at the maximum satisfaction of its customers by guaranteeing them professionalism, availability and timeliness. The choice of suppliers and the determination of the relative purchase conditions are left to the competent corporate functions which act on the basis of objective and impartial criteria, based mainly on the evaluation of reliability, quality, efficiency and cost-effectiveness. In any case, the Agency requires that suppliers operate in compliance with all applicable laws, including, but not limited to, employment laws relating to the work of minors, minimum wages, compensation for overtime, hiring and to safety at work. The choice of any commercial partners also falls on operators who meet the criteria of ethics, reliability, good reputation, credibility in the reference market and professional reliability.

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•Relations with institutions and other organizations- Relations with the institutions are based on the utmost rigor, transparency and fairness in compliance with institutional roles. Contributions, direct or indirect, to parties, trade unions, political exponents / candidates or to events with political purposes or funding or in any case relations with national or foreign organizations, associations or movements that pursue, directly or indirectly, purposes prohibited by law are not allowed, contrary to ethics or public order or that violate the fundamental rights of the person.

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•Relations with the Public Administration- Relationships and relations with public administrations with the PP.UU. and, in any case, any relationship of a public nature is inspired by the most rigorous observance of the applicable regulatory provisions and the principles of transparency, honesty and correctness. The Recipients must not improperly influence the decisions of the officials who negotiate or decide on behalf of the PA. The management of relations with officials, exponents or representatives of the PA is in any case reserved to the Owner of the Agency. It is expressly forbidden for Recipients to offer or give financial benefits, gifts or other benefits, personal or otherwise, to favor or reward decisions in favor of the Agency, and in any case to recognize benefits such as to generate, in an impartial third party, doubts regarding the relative correctness or adequacy. It is forbidden to use documents containing untrue data in relations with the PA or to omit relevant information in order to obtain, in the interest of Vitamin C, national or EU contributions or funding. It is not allowed to use any public grants received for purposes other than those for which they were assigned. It is forbidden to exploit existing or alleged relationships with a public official or with a person in charge of a public service in order to be given or promised unduly money or other financial advantage as consideration for illicit mediation towards the public official or person in charge of a public service. , or to remunerate him in relation to the performance of an act contrary to the duties of his office, or even to the omission or delay of an act of his office. Inspection visits by the supervisory authorities and relations with the judicial authority must be managed in a spirit of collaboration, fairness and transparency, with absolute prohibition against hindering the regular performance of the verification activity by concealing or destroying documentation.

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FINAL PROVISIONS

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Reports

The Owner of the Agency has the task of supervising compliance with this Code of Ethics.

Each Recipient may address any doubts regarding its interpretation to the Owner of the Agency and may report violations or alleged violations of the provisions of this Code of Ethics, of which he becomes aware in the context of existing relationships with Vitamin C. The reports must be made by direct communication to the following e-mail address, dedicated to whistleblowing reports: claudia.v@vitaminac.net

Maximum confidentiality of the identity of the whistleblower will be guaranteed in the management of reports. In any case, the whistleblower will not undergo any retaliatory action or be discriminated in any way in relations with Vitamin C, for having reported in good faith a violation, whether or not alleged, of the Code of Ethics.

 

Consequences in case of violation

Failure to comply with the Code of Ethics constitutes a breach of the obligations deriving from the employment relationship and in the most serious cases may lead the Agency Owner to the adoption of sanctions also of a disciplinary nature.

If the violation of this Code of Ethics is put in place by third parties, the Owner of the Agency may take any remedy of a contractual nature (provided for in specific clauses included in the contracts, for example withdrawal and termination) or, in the most serious cases, of a compensatory nature.

 

Dissemination of the Code of Ethics

Vitamina C undertakes to disseminate the Code of Ethics as widely as possible to all Recipients, including through publication on its website: www.vitaminac.net