CODE OF ETHICS

An other “quantum leap”.

1. GENERAL VIEW

The current times are characterized by great changes, both due to the globalization of economic and financial systems, both due to socio-political situations characterized by social mobility and cultural pluralism, linguistic and religious, and finally favoured by an information system putting online in real-time imposing mass of information, among which it is increasingly difficult to unravel what can be useful because true and reliable, from what it may be useless or even harmful..

The business system is facing unprecedented and global challenges, which put a strain on the capacity for innovation and adaptation of organizational structures, among which the Human Factor stands out for its centrality, but also elements of fragility. The working dimension becomes a ground on which we measure the capacity of individuals and the companies themselves to "stay in the global competition", maintaining corporate and productive identity, inspired by the profound values of cooperation among all and solidarity. 

In this challenging and stimulating context and time, DVO S.P.A. decides to take another ethical, organizational and managerial "quantum leap", by adopting the "model 231".

2. COMPANY PROFILE

DVO S.P.A. (hereinafter DVO S.P.A.) is an emerging brand in the field of office furniture. Incorporated in 1990 to produce office furniture in laminate and melamine, it has developed an alternative idea to the trend of manufacturers in the sector, which has quickly become the strength of the company: to offer its customers the prompt delivery service. This idea has been complemented by an characterizing and innovative design embracing a wide range of furniture, allowing the choice of operative and executive. The company has maintained and expanded the offering with the inclusion in the catalogue of numerous shapes and colours, the study and development of industrialization for easy mounting, the computer aided design system to support customers and an efficient service, succeeding with this policy to curb the negative effects of the crisis.

After the reorganization in 1993, DVO S.P.A. began a rapid growth: both in terms of market penetration to distribute its products in over 100 countries and numbering about 1,071 customers, whether in sales, judiciously balanced between domestic and foreign market. The activity is carried out in an industrial compound recently built with an area of about 56.000m2 of which 33.000m2 covered by modern facilities and efficient materials handling systems allow for easy management and careful control of the products.

The company is characterized by a young and dynamic management, and it participates at the most important exhibitions of the sector in Milan, Madrid, Moscow, Cologne, Dubai and through distributors in other important showcases around the world.

The distinctive features of DVO S.P.A. common to all these clients are:
- modern design;
- ease and speed assembly;
- wide range of operational and management products, in different sizes and finishes;
- efficient service;
- computer-aided design.

3. COMPANY VALUES

DVO S.P.A. has always paid particular attention to compliance with the European standards in terms of safety, product reliability and environment. For this, all the items in the range are tested by authorized laboratories, ensuring customers the quality of products offered. In environmental issues, DVO is pursuing the path of least impact ecological processes with environmentally sustainable. Hence the collaboration with organizations such as the Green Building Council "GBC", for the selection of products that can contribute, for example, the LEED rating.

In February 2014, DVO S.P.A. got the "UL Environment" the prestigious GREENGUARD certification, in order to contribute more to the rating required by LEED projects. The environment variable is for DVO S.P.A. a cardinal principle of the code of ethics and that convinced its of the importance of investing in clean technologies aimed at saving and a more rational use of energy resources. To this end it is equipped with a photovoltaic system for the annual production of 1,170,000 kilowatt hours (kWh) and a plant for the recycling of rainwater.

Confirming its commitment to the improvement, after obtaining the UNI EN ISO 9001 (QUALITY), ISO 14001 (ENVIRONMENT) and EMAS registration, DVO has realized a "business system management SAFETY AND HEALTH IN PLACES JOB ", in accordance with the standards of OHSAS 18001, obtained the prestigious certificate of excellence by ICILA. Another milestone has been reached in February 2012 with the certification of the Chain of Custody according to the FSC standards (Forest Stewardship Council).

4. THE ETHICAL VISION

The Ethical Vision shared and advocated by DVO S.P.A. is marked to  conjugation of goals that contribute harmoniously to the improvement of business results and the achievement of goals, both for customers and suppliers, and for their employees, with the aim of achieving the best economic and trade result : a business for an order to improve business results, the conditions of life and work of all employees and to the social cohesion of the territory. The Ethics proposed here, then, is respectful of all those co-interested in the business enterprise, without any prevarication and privileges.


All DVO S.P.A. activities have to be done within the law, within a framework of fair industrial and commercial competition, marked by honesty, integrity, fairness and good faith, respecting the legitimate interests of customers, suppliers, employees, the commercial and financial partners, and the communities in which DVO S.P.A. is present with its activities. Everyone working in DVO S.P.A., without distinction or exception, are committed to complying and ensuring compliance with these standards as part of their duties and responsibilities. Under no circumstances can the conviction of acting for the benefit of DVO S.P.A. can justify the adoption of practices contravening these principles. Because the complexity of international situations where DVO S.P.A. is operating, it is important to clearly define the set of values ​​that recognizes, accepts and shares, and all the responsibility that assumes both internally and externally . For this reason the present this "Code of Ethics", which contains a set of principles and rules whose observance by the operators is essential for the proper functioning, reliability and reputation of DVO S.P.A.


The Code of Ethics is not only a collection of Guidelines to ensure appropriate behaviour inspired by a correct view of action of the people in the company, but it is also a strong reminder to the principles which guide human action. Like any other Sorting, also the Code of Ethics is guided by explicit and clear basis that put the person, which works with colleagues in workgroups and complex, at the centre of a project aimed at a common Well responsive to logic intrinsic profitability of the enterprise, and that must be a collective value to be shared and protected all those who work in DVO S.P.A. The Code of Ethics is therefore proposed to mark the values ​​of honesty, fairness, integrity, loyalty and professional rigor operations, behaviour and the way we work, either internally in DVO S.P.A., either in relations with external actors, focusing on attention the respect of the laws and regulations of the countries where DVO S.P.A. work, and compliance with company procedures.

The Board of Directors of DVO S.P.A., adapting to the most advanced standards of Corporate Governance, adopts this Code of Ethics in order to ratify the aforesaid principles of ethics and transparency, and in order to reconcile the pursuit of competitiveness with ensure sound competition. DVO S.P.A. will check compliance with the Code of Ethics, preparing appropriate means of information, prevention and control, and ensuring the transparency of the operations and conduct, and intervening, if necessary, with corrective actions.

5. GENERAL PRINCIPES

5.1 Recipients
Are hereinafter referred to as "Recipients" the subjects concerned by the regulations of this Code of Ethics, identified as the Directors and Shareholders of DVO S.P.A., all employees, and all those who, directly or indirectly, permanently or temporarily, they establish relations and relationships with the Company, or otherwise cooperate in achieving the aims and objectives, in all Countries in which it operates. The business of DVO S.P.A. is based on the principles of fairness and transparency. For this purpose, the transactions between the various corporate entities comply with criteria of substantial and procedural fairness, according to pre-established standards of conduct for their execution, properly communicated to the market. Members of the Board of Directors, defining the Company's objectives, are inspired by the principles of this Code. It is primarily up to the manager to give substance to the values and principles of the Code, by assuming responsibility for inward and outward, and by enhancing trust, cohesion, a sense of belonging and team spirit. 


Employees of DVO S.P.A., as part of the due respect of the law and regulations, adapt their actions and conduct to the principles, objectives and commitments under this Code. All the actions, operations and negotiations carried out and, generally, the conduct engaged in by employees of DVO S.P.A. in carrying out their work, are inspired by the highest correctness in terms of management, completeness and transparency of information, the legitimacy in both form and substance, and clarity and truthfulness of their accounting, according to relevant regulations and internal procedures. Each employee must work appropriately to the responsibilities assigned and recognized professionalism, and must act to protect the reputation and image of DVO S.P.A. Each Recipient must know the Code of Ethics, contribute actively to its implementation and report any deficiencies to the appropriate reference function.  To achieve full compliance with the Code of Ethics, each employee, if it becomes aware of situations that actually or potentially, may represent a significant breach of the Code of Ethics, he must promptly report to your manager and/or one of the Bodies of reference described in paragraph 5.6.


5.2 DVO
’s commitments
DVO ensures, through the designation of specific functions ("Bodies of reference"):

- the widest dissemination of the Code to the Subjects;
- updating the Code, in order to adapt to evolution of civil sensitivity and of regulations relevant for this Code;
- the execution of checks to any notice of violation of the Code;
- the assessment of the facts and the subsequent implementation of appropriate sanctions, in case of violation found;
- that no one may suffer any retaliation whatsoever for having provided information regarding possible violations of the Code or of reference standards.


5.3 Obligations for all employers 
All employees are expected to know the rules of the Code and related laws that regulate the activity carried out as part of their function. Employees of DVO S.P.A. are required to:

- refrain from conduct contrary to these rules;
- refer to their superiors or to the Human Resources Service in case of need for clarification on the application of these rules;
- immediately report to their superiors or to the Human Resources Service any information, obtained directly or reported by others, concerning a possible violation, or any request made to him to violate them;
- in cases of alleged violations of particular gravity, the employee is obliged to address the report directly to the Management.

5.4 
Additional requirements for the Managers of the Units and business Functions
Each Head of Unit / Function Business has the obligation to:
- representing through their behaviour an example for their employees and encourage them to respect the Code and the reference procedures;
- work to ensure that employees understand that compliance with the rules of the Code, as well as the procedures and safety standards, is fundamental for the quality of their work and of employment in its ethical dimension;
- carefully select, within its competencies, internal and external collaborators in order to prevent assignments being given to people who are not fully reliable in their commitment to observe the rules of this Code and procedures;
- take prompt corrective measures, whenever necessary.

5.5 V
alence of the Code with third parties
All employees of DVO S.P.A., because of their skills, in their relations with external parties must:
- adequately inform them about the commitments and obligations imposed by this Code;
- require compliance with the obligations directly concerning their activities;
- adopt appropriate internal and external, if authorized, in the case of non-fulfilment by third parties of the obligation to comply with the rules of this Code.

5.6
Reference Bodies
Bodies of reference for the application of the Code are:

- Directors (as General Management and / or Chief Executive Officer);
- Human Resources Service,
with the task of promoting awareness of the Code within DVO S.P.A., providing the necessary explanations and addresses training and, if necessary, take the appropriate sanctions in case of violation of the Code, as well as investigating reports of possible violations, promote investigation and inquiry procedures.

5.7 Contractual value of the Code
The Code is an integral part of the rules of employment. Compliance with the Code is an essential part of the obligations of the Employees of DVO S.P.A. Violation of the Code may constitute a breach of the primary obligations of the employment relationship or a disciplinary offense, with all legal consequences, including the preservation of employment, and may result in actions for damages caused by that infringement. For Recipients not employees, compliance with the Code is a prerequisite for the continuation of the professional/collaboration relationship outstanding with DVO S.P.A.

6. CONDUCT IN BUSINESS MANAGEMENT

6.1 General business management 
In business dealings, DVO S.P.A. is inspired by the principles of loyalty, fairness, transparency, efficiency and open to the market. Employees of DVO S.P.A. and contractors acting for or on behalf of the Company are required, in dealing with the public administration, in an ethically founded and law-abiding, marked by an explicit and binding prohibition to resort to illegitimate favouritism, operating with transparency, clarity, fairness and efficiency in relationships and in trade and promotional relations. Recipients are also required to behave in line with company policy of DVO S.P.A., which can never be translated, including those used to achieve the company's goal, in acts contrary to law, regulations or the corporate procedures adopted in respect of individual functions.

6.2 
Gifts, freebies and other benefits
In relations with clients and suppliers and third parties in general, are not permitted: offers of money, gifts or benefits of real or apparent undue advantages of any kind (e.g.: promises of economic benefits, favours, recommendations, promises of job offers , etc.). In any case, the acts of commercial courtesy of modest value are permitted provided if, anyway, they do not compromise the integrity and reputation, and they don't influence the independent judgment of the Recipient. Recipient receiving gifts of any nature and consistency value, must notify it to his manager or one of the organs of Reference under point 5.6.

6.3 
Conflict of interest 
Recipients (directors, shareholders, all employees, and all those who, directly or indirectly, permanently or temporarily, establish relations and relations with the Company, or otherwise cooperate in achieving the aims and objectives, in all nations in which it operates) must avoid situations and/or activities that may lead to conflicts of interest with those of DVO S.P.A. or that could interfere with their ability to make impartial decisions, in safeguarding the best interest of the Company.
If the Recipient may experience an objective situation of conflict with the interests of DVO S.P.A., it is necessary that the recipient communicates it immediately to his superior and/or any of the organs of Reference, and he refrains from any activity related to the source of the conflict situation.
In the relationship between DVO S.P.A. and the third parties, Recipients must act in accordance with ethical and legal rules, with explicit prohibition to resort to illegitimate favouritism, collusion, corruption or solicitation of personal advantage for themselves or for others.
They are obliged to promptly report to their superiors and/or any of the Organs of Reference, any information that could imply or predict a situation of potential conflict of interest.
By way of example, the following situations could create a conflict of interests:
- have economic and financial interests (substantial holding of shares, professional appointments, etc.) even through family members, with customers, suppliers or competitors;
- carry out work with customers, suppliers or competitors, even by family members;
- accept money, gifts or any kind of favours from persons, companies or organizations that have, or intend to have, business relations with DVO S.P.A.;
- using their position in the Company or information acquired during their work, so as to create a conflict between personal interests and those of business.

6.4 
Relations with Shareholders 
DVO S.P.A. pursues the creation of value for all its shareholders, protecting the interests of the Company and its shareholders as a whole, without any preference.

6.5 Relations with Suppliers
The selection of Suppliers and formulating The selection of suppliers and the formulation of the conditions of purchase of goods and services for companies of DVO S.P.A. is driven by values and parameters of competition, objectivity, fairness, impartiality, fair price, quality of goods and/or services, carefully assessing the guarantees of assistance and the range of offers as a whole.
Procurement processes must be based on the search for maximum competitive advantage for DVO S.P.A. and on fairness and impartiality towards each Supplier in meeting requirements. Collaboration of Suppliers for the constant meeting the needs of customers in terms of quality and delivery times, must also be sought.
The signing of a contract with a Supplier must always be based on extremely clear relationships, avoiding, wherever possible, the acceptance of contractual obligations involving forms of dependence with the contracting Supplier.
The need to pursue the maximum competitive advantage for DVO S.P.A., must necessarily ensure that suppliers adopt operational solutions in line with the current regulations and, more generally, with the principles of protection of any person, product, health, safety and environment involved.

6.6 
Relations with Clients
DVO S.P.A. pursues its success on the national and international markets, by offering products and services of high quality at competitive conditions and in compliance with the laws protecting competition.
Each Recipient, in the relationship with customers and in compliance with internal procedures, must aim for maximum customer satisfaction by providing, among other things, exhaustive and accurate information about the products and services provided, so as to encourage informed choices.

6.7 Proper use of company assets 
Each recipient is responsible for protecting the resources entrusted to him and has a duty to inform the governing bodies of Reference of any threats or damaging events DVO S.P.A.
In particular, each recipient must:

- work diligently to protect corporate assets by acting responsibly and in line with the operating procedures, for governing the use of them;
- avoid improper use of company assets that may cause damage or reduce their efficiency or otherwise be contrary to the interest of the company;
- obtain the necessary authorizations, in case of use of the asset outside the company business.

The growing dependence on information technology asks to ensure the availability, security, integrity and maximum efficiency of this particular category of equipment.

Each Recipient is required to:

- do not send threatening and insulting e-mail messages; do not use low quality language or inadequate style, inappropriate or unwanted comments, that may cause offense to the person and/or damage the corporate image;
- avoid spamming and "chain letters", which can generate a traffic data/information/process of the company computer network, such as to significantly reduce the efficiency of the network, with negative impact on productivity;
- do not to surf websites as opposed to rules and regulations and/or with indecent and/or offensive subjects (as an example: child pornography sites and similar);
- scrupulously adopt policies regarding corporate security, in order do not to compromise the functionality and security of information systems;
avoid loading borrowed or unauthorized software on corporate systems, and never to make unauthorized copies of licensed programs for personal, corporate or third parties uses. In particular, DVO S.P.A. prohibits any use of the information systems that may be infringing the legislation, as well as aggression against the freedom, integrity and dignity of the people, especially to children. The use, even involuntary, of these goods, for any purpose outside of the business, it can cause serious damage (economic, image, competitiveness, etc.) to the Company, with the aggravating circumstance that improper use can lead to the company potential criminal and administrative sanctions for any crimes, and configure the need to take disciplinary action against the Recipients.

7. RELATIONS WITH EXTERNAL PARTIES

7.1 Relations with Public Institutions 
Relations with Institutions and Public Organisations, necessary for the development of DVO S.P.A. business programs, are reserved exclusively to delegated corporate functions. Reports must be the utmost transparency, clarity, correctness, and they will not lead to interpretations partial, false, ambiguous or misleading information by the institutional public with whom relations are maintained for various reasons.
Gifts and acts of courtesy and hospitality extended to representatives such as: public officers or public service entities, are permitted when their value is limited and that they can not be interpreted by third parties as aimed at obtaining undue advantages. In any case, these expenses must be authorized and adequately documented.
Particularly, in dealing with Public Entities for access to subsidized funds, DVO S.P.A.:
- refuses any behaviour aimed at achieving the contribution unduly by deceit or omission of required information;
- prohibits allocate the received grant for purposes other than those for which it was provided.

Relations with mass media
The relationship between DVO S.P.A. and the mass media are responsibility of the designated company officers and must be carried out consistently with the policy and defined mass media. Any employee of DVO S.P.A. receiving an interview or declarations request, relating to the Company by any organ of the press or communication, shall inform the direction in advance and with them he agrees on the desirability and content of the interview itself.

8. TREATMENT OF CONFIDENTIAL INFORMATION, EITHER INTERNAL EITHER ADDRESSED TO THE MARKET.

With particular reference to confidential information in order to prevent their communication taking place in a selective, untimely, incomplete or inadequate, DVO S.P.A., in all its branches and corporate structures, it decides to maintain a proper and full control at the level of Directors. Therefore, all information regarding products, services, organizational, know-how, management, economic and financial aspects will not be disclosed outside, under any circumstances, without prior verification and authorization of the Executive Board.

9. STAFF POLICIES

9.1 Management and development of human resources.
Human resources are a key and essential factor for the company's existence. Dedication and professionalism of the employees are crucial values and conditions for achieving the objectives of DVO S.P.A.
DVO S.P.A. is committed to developing the abilities and skills of each employee so that the energy and creativity of each one can have full expression in the performance and achievement of the objectives contained in the corporate purpose and in their own job.
DVO S.P.A. gives all employees the same opportunities for professional growth by ensuring that everyone can enjoy equal treatment based on merit, without any discrimination.

The competent managers shall:
- to adopt merit, competence and strictly professional criteria, in all decisions relating to each employee;
- to search, select, hire, train, pay and manage employees without discrimination of any kind:;
- to create a working environment where personal characteristics do not give rise to discrimination, and, in no way, to a phenomenon known as mobbing. To this end, it implements all initiatives to monitor the business climate, enhancing the indicators acquired in order to work for a continuous improvement. Each Recipient must actively work to maintain a climate of mutual respect for the dignity and reputation of each person.
Recipients are also required to keep personal data of which they acquire knowledge during their work, the most appropriate treatment in order to protect privacy, the image and dignity of individuals. DVO S.P.A. undertakes to spread and consolidate a culture of safety, developing sensitivity to the acquisition of a full awareness of risks, promoting responsible behaviour by all employees, and working to safeguard the health and safety of workers, especially with preventive actions. The company activities must be carried out in full compliance with current regulations on the prevention and protection. Operational management must refer to advanced criteria of environmental protection and energy efficiency, pursuing the improvement of health and safety at work. DVO is also committed to ensuring the protection of working conditions in the protection of the mental and physical health of workers, in respect of his moral personality, preventing the latter from suffering illicit influences or undue discomfort.
Therefore DVO S.P.A. counteracting any behaviour or attitude that discriminates or harms a person, their beliefs and preferences (e.g.: in the case of insults, threats, isolation or excessive intrusiveness, professional limitations). In the context of its activities, the Company will endeavour to ensure that rights under the Universal Declaration of Human Rights are guaranteed in Italy and in the Countries in which it operates.
In any Country where it operates, DVO S.P.A. rejects the exploitation of child labour. In addition to full compliance with the regulations laid out in individual Countries, it promotes the protection of worker's rights, trade union freedoms and the rights of association. Any violation of the provisions of this article shall be submitted to the Human Resources Department immediately.

9.2 Respect for colleagues 
DVO S.P.A. tolerates no kind of harassment of a colleague, from sexual ones, meaning such: subordination of salary or career prospects acceptance of sexual favors. Moreover it does not allow advances of private interpersonal relationships, proposals insistently, notwithstanding an explicit or clear distaste of the person involved, which are perceived as discomfort or elements of disturbance at least.

9.3 
Abuse of alcohol and drugs
DVO believes it is essential that each employee contribute personally to maintaining a work environment respectful of the moral principles and of the sensitivity of colleagues. Therefore, be deemed aware of the risk of infringement of such connotations environmental and behavioural:
- working under the effects of alcohol abuse, drugs or substances with similar effect;
- to consume or give narcotics during work performance, for whatever reason. Such behaviour will be appropriately reported and punished.

9.4 
Smoking
In view of the current legislation, and the desire to create for its employees and visitors a healthy and comfortable environment, DVO S.P.A. has provided the general ban on smoking in the workplace, except in designated areas.

10. TRANSPARENCY OF ACCOUNTING AND INTERNAL CONTROLS

10.1 Accounting Reports
All activities and actions performed and carried by the Recipients as part of their work, must be verifiable. Accounting transparency is based on the truthfulness, accuracy, completeness and reliability of the documentation of the management proceedings and related records. Each Recipient shall cooperate to ensure that acts of management are correctly and promptly shown in the accounts. For each transaction is stored and archived adequate supporting documentation of the activity, in order to allow easy accounting report, identification of the various levels of responsibility, and accurate reconstruction of the operation. Each record shall reflect exactly what is shown by the supporting evidence. Recipients who become aware of omissions, falsifications, alterations or negligence of the supporting documentation, they are required to report the facts to their superiors or to one of the Reference Bodies, set out in paragraph 5.6.

10.2 Internal controls 
It is will of DVO S.P.A. spreading, at all levels of its organization, a culture aware of the importance of an adequate system of internal control. Particularly, the internal control system must facilitate the achievement of corporate objectives and, therefore, it must be oriented towards improving the efficiency and effectiveness of production and management processes. All Recipients are responsible for the proper functioning of the control system, in their respective functions. Each employee is responsible for the Company's tangible and intangible assets, which are necessary for the work performed.

10.3 Anti-money laundering and anti-terrorism 
In accordance with current regulations on the subject, God is working to prevent the use of its economic - financial system for purposes of money laundering or terrorist financing (or any other criminal activity) by its customers, suppliers, employees and counterparties with which it relates in the conduct of its activities. So, the company verifies with the greatest possible care available any information on business counterparts, suppliers, partners and consultants, in order to ascertain their respectability and legitimacy of their activity, before establishing business dealings. DVO S.P.A. cares also that the operations of which it is part, they do not show, even potentially, the risk of favoring the receipt or replacement or the use of money or assets derived from criminal activities.

11. ACCEPTANCE, EFFECTIVENESS AND CHANGES

This Code of Ethics may be subject to periodic study, updating, modification or review by the Board of Directors of DVO S.P.A., also on any proposal of the Board of Auditors or of the Supervisory Board. This Code of Ethics is adopted by the Board of Directors of DVO With immediate effect from the same date.

12. PROCEDURE FOR MANAGING REPORTS AND COMPLAINTS CONCERNING VIOLATIONS OF THE PRINCIPLES AND RULES DEFINED AND / OR RECOGNIZED IN THIS CODE OF ETHICS

12.1 Subject

Falling within this procedure, the complaints, claims and reports (hereinafter "complaints") regarding the cases of alleged fraud, violations of ethical and behaviour principles of Code of Ethics, and the irregularities or negligence in accounting, internal control in auditing (following "violations").
Under Article no.2359 of Italian Civil Code, both the complaints received from internal employees, and from external parties to DVO S.P.A. are taken into account. DVO is committed to safeguarding the anonymity of whistle-blowers and to ensure that the employee reporting the violation is not subject to any retaliation.


12.2 
Regulatory Framework
The main internal reference standards are as follows:
Code of Ethics
Disciplinary System

12.3 Procedural process
The complaint of the violation may be made only in writing by letter or by e-mail, signed or anonymous, to one of the following addresses:

by regular mail addressed to DVO S.P.A. – Via XX Settembre, 272 – 33080 Roveredo in Piano (PN) attention of the Management and the Service of Human Resources;
by e-mail to the following address francesco.pizzol@dvoffice.com 
However, this procedure encourages both employees and external parties to refrain from anonymous complaints, because an investigation would be made difficult in the absence of an "identified" source of information.
All complaints of violation received in the company must be sent to the attention of the Human Resources Service, regardless of the recipient and the source;
With the support of other competent corporate bodies, in particular the Human Resources Service, the Management will ensure that all complaints received are:
- recorded and stored;
- qualified (storage or activation of investigations), with an explanation of the reasons which led to the decision;
- where necessary, subjected to the verification process with information to stakeholders.
In order to enable the checks, the Management may, in its discretion, take advantage of any corporate function which it considers possess the professionalism and/or the knowledge to provide the necessary support.