Ethical code

DevIBrain believes that compliance with ethical rules and transparency in the conduct of business are a necessary condition, as well as a competitive advantage, to pursue and achieve its objectives.

To this end, DevIBrain promotes the creation of an environment characterized by a strong sense of ethical integrity, in the firm belief that this contributes decisively to the effectiveness of policies and control systems, influencing behavior that could escape even the most sophisticated. supervisory mechanism.

DevIBrain has therefore deemed it appropriate and necessary to adopt and issue a Code of Ethics that expresses the values which must be based on the conduct of all those who, at various levels of responsibility, contribute with their actions to the performance of its business, including consultants, commercial partners, suppliers and / or external collaborators, however named.

These values are mainly:

• moral integrity, personal honesty and correctness in internal and external relationships;
• transparency towards shareholders, related stakeholders and the market;
• respect for employees and the commitment to enhance their professional skills;
• social commitment;
• the protection of health, safety and the environment;

and, more generally,

• the refusal of any conduct which, although aimed at achieving a result consistent with the interest of DevIBrain, presents aspects that are not compatible with the laws and behavioral rules in force within the Company.

Anti-corruption code of conduct

DevIBrain adheres to and promotes policies consistent with laws and standards of legality for the prevention of corruption and transparency in business relations (hereinafter also Anti-corruption Laws), at national and international level.

The Anti-Corruption Laws qualify as illegal – for DevIBrain personnel, for Business Partners and for anyone who carries out activities for or on behalf of the Company – the promise, offer, payment or acceptance, directly or indirectly, of money or other benefits, for the purpose of obtaining or maintaining a business and securing an unfair advantage through behavior of public and private counterparties contrary to professional and / or office duties.

In particular, in order to prevent the conduct prohibited by the Anti-Corruption Laws, the Company has decided to adopt a specific Anti-Corruption Code of Conduct, which is integrated within a broader regulatory compliance program adopted by the company. The Anti-Corruption Code of Conduct, therefore, aims to provide all staff with the rules to follow to ensure compliance with the Anti-Corruption Laws.

Model 231/2001

With the adoption of the organization, management and control model pursuant to Legislative Decree 8 June 2001, n. 231 (the “Organizational Model“) which took place with the resolution of the Board of Directors on February 1, 2022, DevIBrain S.r.l intended to pursue the following purposes:

1. ensure that the company activities and the processes in which they are articulated are carried out in compliance with the ethical values to which our Company adheres, as described in the Code of Ethics, which constitutes the fundamental “Charter of values” which every company activity must be inspired by;
2. condemn any form of unlawful behavior by all those who operate in the name, on behalf and in the interest of the Company as contrary, in addition to the provisions of the law, also to the ethical principles adopted by the Company and to which the Company intends to abide;

• create in all its recipients the awareness that the violation of the provisions of the Organizational Model may constitute an offense subject to penalties and administrative sanctions, which can be inflicted not only against the natural person, but also against the Company;

1. guarantee the Company, thanks to the control and monitoring of company activities in the areas of activity at risk, the concrete and effective possibility of intervening promptly to prevent the commission of the crimes themselves.

To guarantee the constant and effective implementation of the Organizational Model, the Code of Ethics and the Anti-corruption Code, a disciplinary system is envisaged aimed at sanctioning any violations of the Organizational Model, the Code of Ethics and the respective provisions, both by employees of the company. that by consultants, collaborators or commercial partners.

The Company has also set up a Supervisory Body with the task of supervising the functioning and observance of the Organizational Model and the Code of Ethics.

All recipients of the Organizational Model are required to report to the Supervisory Body any violations of the provisions of the Organizational Model, the Code of Ethics or the Anti-corruption Code of which they are aware.

Reports to the Supervisory Body must be addressed to:

devibrain@pec.it .

Reports may also be made by post to the Supervisory Body at the Company’s headquarters at the following address:

DevIBrain S.r.l

Via Francesco Coghetti n.6, 24128 Bergamo (BG)

Att.ne Organismo di Vigilanza

Indicating on the envelope the words “PERSONAL AND STRICTLY CONFIDENTIAL – NOT TO BE OPENED”.