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Etic code

ART. 1

DEFINITIONS

Code of Ethics: enunciation of ethical principles and values of Auction Italia Investments and consequent criteria of conduct to which the Recipients are kept, ie collaborators, consultants, suppliers, partners and any other person who can act in the name and on behalf of the Auction Italy Investments.

Steering Committee: administrative and decision-making body of Auction Italia Investments.

ART. 2

GENERAL PRINCIPLES

1. The Code of Ethics asserts principles and values that inspire the ethical behavior of the professional activity of the Collaborators and, in general, of the Recipients.

2. This Code is a set of principles and rules whose observance by the Recipients is an obligation of fundamental importance for the professionalism, quality, reliability and reputation of Auction Italia Investments.

3. This Code is based on the rules and principles of the Code of Conduct for Lawyers, the Code of Privacy and the Professional Law.

4. The provisions of the Code of Ethics integrate the behavioral and deontological rules that the Recipients are required to observe, the regulations in force, the employment contracts, the internal procedures, as well as the codes of conduct to which Auction Italia Investments should adhere or internally.

5. Behaviors that, despite being implemented in compliance with the provisions of this Code, are in violation of the substance and in any case lead to results incompatible with the provisions of this Code.

6. All Recipients of the Code of Ethics must know, observe and comply with the provisions contained therein, with correctness and transparency of the behaviors that must be based on cooperation and mutual collaboration.

7. In no case will the pursuit of the interest of Auction Italia Investments or the achievement of an advantage for the same may justify the adoption of an unlawful or illegitimate conduct or otherwise contrary to the principles contained in this Code.

ART. 3

MISSION

1. Auction Italia Investments offers expertise and professionalism to meet the needs of the client, through resolutive answers to contingent problems and through analysis, advice and perspectives for future needs.

2. Auction Italia Investments has a structured organization in different areas constantly updated with each other, in the profitable synergy perspective of group work for a global consultancy that responds adequately to requests.

3. Auction Italia Investments intends to promote and communicate to the outside the guiding values that distinguish the working methodologies and for this reason the Code of Ethics is published on-line on the home-page of the website www.auctionitalia.it and displayed on paper in the offices of the society.

ART. 4

FUNDAMENTAL VALUES AND PROFESSIONAL DEONTOLOGY

The fundamental values which inspire and conform the professionalism and activity of Auction Italia Investments are:

1. PROFESSIONALISM AND COMPETENCE

Collaborators are obliged to update and continue their professional training, with the aim of providing an adequate professional contribution in relation to the task assigned and in the area of competence. Consequently they are obliged not to accept assignments that they know they can not carry out with the necessary competence or for which they are not able to assure a complete and adequate consultancy and assistance.

According to this perspective, Auction Italia Investments promotes the growth and professional preparation of Collaborators, through participation in courses, conferences, publications and updates on regulatory changes concerning the individual areas of specialist expertise.

2. PREGNANCY AND CONFIDENTIALITY

The Recipients are required to comply with the obligation of professional secrecy and to ensure the utmost confidentiality in relation to the news and information learned from their customers and stakeholders with whom they come into contact, in compliance with current legal regulations and those expressly provided for the processing of personal data.

The commitment of Auction Italia Investments is aimed at creating the conditions for confidentiality to be maintained by all Recipients.

3. CORRECTNESS AND LOYALTY

Collaborators must inspire their professional activity to fully and substantially respect the principle of fairness and loyalty towards other collaborators, the client and third parties.

4. QUALITY

Auction Italia Investments directs its business to the highest quality standards for customer satisfaction. The main objective that Collaborators must pursue is to create quality relationships with customers. From this point of view, relational quality, in the assistance and consultancy activities, means adopting highly reliable behavior, availability, preparation and transparency, combined with the use of understanding and interaction skills.

5. DEONTOLOGY

The Code of Ethics is complemented by the Code of Conduct of the legal profession, it is also based on non-legal rules, and is aimed at the moral and professional sensitivity of individuals. All participants in the organization and operation of Auction Italia Investments have a moral responsibility for the dissemination and application of the values expressed in the Code of Ethics, with reference to the functions assigned to them.

6. PROFESSIONAL OBJECTIVITY

The Collaborators act in compliance with the facts established with the professional work, reject attitudes of part or sectarians, influences and influences that can alter the facts for external interests.

Objectivity implies that the Collaborators provide the recipient of professional services with the advantages and disadvantages of the proposed technical solutions.

7. RESPECT FOR THE PERSON

Auction Italia Investments protects the moral integrity of its Employees and Collaborators, guaranteeing the right to working conditions that respect the dignity of the person and the contract of work or collaboration.

Auction Italia Investments prevents and contrasts acts of psychological violence or attitudes or behaviors that are discriminatory or damaging to the person, his convictions or conditions, bullying, harassment and any form of discrimination on grounds related to sex, sexual preference, race, status health, nationality, political and trade union opinions, religious beliefs.

ART. 5

CONFLICT OF INTEREST

1. The Recipients shall pursue, in carrying out the collaboration, the objectives and general interests of Auction Italia Investments.

2. Recipients must inform, without delay, taking into account the circumstances, situations or activities in which they may hold interests in conflict with those of Auction Italia Investments (or if such interests are the next joint holders), and in any other case in which there are significant reasons of convenience.

3. The Recipients respect the decisions that are taken on in this regard by the Steering Committee.

ART. 6

ETHICAL PRINCIPLES OF BEHAVIOR IN INTERNAL RELATIONSHIPS

Collaborators are required to deal honestly with the internal relationships of Auction Italia Investments, in good faith and with the utmost transparency, facilitating the dissemination of all elements that may favor or hinder the exercise of the profession and its future developments.

They are manifestations of respect and correctness, for example the attention to the colleague and the observance of the rules of respect, of care, cordiality, abstention from initiatives that contribute to attracting the client assisted by others in their exclusive sphere, the recognition and valorisation of the qualities and talents of the other Collaborators, not to harm others for their own interests and advantages.

Behaviors and conflicts that violate or may cause the rules of the Code of Conduct or of this Code of Ethics to be violated should be avoided.

ART. 7

ETHICAL PRINCIPLES OF BEHAVIOR IN EXTERNAL RELATIONS

1. Collaborators, in the exercise of their activity, must respect all the fundamental values of this Code. They are also required to use the utmost clarity in relations with the customer, or simply to illustrate the essential elements and any risks associated with the practice that is entrusted to them. The relationship with the customer is essentially based on trust and, therefore, the recipients of the code must adopt professional behaviors that demonstrate seriousness, availability, professionalism and respect towards the customer.

2. In relations with the Magistrates, the delegated professionals, custodians and third parties the Collaborators must behave respecting the public functions and the decorum of their profession, without assuming attitudes in contrast with their professional dignity.

3. In relations with the press and other media, especially during major professional interventions, Collaborators must use caution especially in relation to the obligation of confidentiality towards the client.

4. Auction Italia Investments manages the process of purchasing goods and services according to the criteria of reliability, affordability and quality of the supplier, and considers the relationship with suppliers to be the starting point for the improvement of processes and services. With this in mind, relations with suppliers require actions that are consistent with the Code of Ethics.

ART. 8

PRIVACY PROTECTION

1. Auction Italia Investments guarantees compliance with the regulations in force regarding privacy and undertakes to protect the confidentiality of all information of any nature or object that it enters in the performance of its business, avoiding any improper use or improper use.

2. Each Recipient is obliged to ensure the utmost confidentiality of the information of the Clients he becomes aware of.

3. Any investigation of ideas, preferences, personal tastes and, in general, the private life of Collaborators, Recipients and customers is forbidden.

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