CODE OF ETHICS.
(following disciplinary measures, in accordance with legislative decree no.231/01)

1.PREAMBLE
The code of ethics is the document that outlines the set of fundamental ethical principles and duties that define the ethical and social responsibility of every member of Lan system srl the code of ethics is the document that outlines the set of fundamental ethical principles and guidelines to which administrators, employees and collaborators must adhere in order to perform their respective functions and work activitie with competence, honesty and Integrity
respect for individuals and laws, trasparency and loyalty, protection of safety and health, safeguarding of property and industrial secrecy are just a few of the vital values that guide the corporate decision-making process, qualify the adherence to roles and fulfillment of tasks, and direct behavior in the work environment

2.THE COMPANY
Lan system was born in the 2000s from the vision of its founder, Luigi Marseglia, to change the way of designing trought virtual experimentation, simulation of manufacting processes and scientific computing.
a shared vision embraced by all individuals who, with ideas, skils and passion have become fundamental elements of the company
since it’s inception, the creation of value and the continuous pursuit of innovative solutions have been the driving force behind daily activities this vision could not have materialized without the human capital, the knowledge of our staff, relationships with developers of cutting-edge software technologies, our loyal customers, and the valuable collaboration of their designers and technicians our task is to daily confirm the role of a strategic partner for each of our clients identifying and developing the best solutions for their specific industrial context through effective and efficient tools the enhancement of intellectual capital and the wealth of skills amoung our clients also allows us to achieve the maximum return on the proposed investments

3.PURPOSE
The world around us is changing to continue growing and to contribute increasingly to development and well-being we must look ahead and move swiftly to prepare for what lies ahead the ethical code serves an effective means to prevent irresponsible behaviors by those who operate on behalf of and for the company the ethical code does not supersede current laws and the existing national collective labor agreement

4.VALUES
Throughout its history, the company has always focused on the customer’s needs through personalized solutions, specialized and methodical consulting services advanced training, research and innovation: developing products and processes with an eye towards the future
this ethical code aims to constantly renew the commitment to the entire company to operate with responsibility , integrity, and a passion for innovation it safeguards the core values and aims to guide the behaviors of all individuals who with various role and functions, constitute the soul of the company
our commitment can be summarized in the following points :
•ability to understand needs;
•intuition, creativity and project skills;
•innovative solutions and reliable and timely services ;
•competence and professionalism;
•use of the best technologies available on the market ;
•respect for contractual commitments
the absolute respect for laws, principles of fairness, confidentiality, correctness, integrity, and good faith characterize and complement the pursuit of objectives

5.SCOPE OF APPLICATION AND RECIPIENTS
The recipients of the ethical code and the resulting rules of conduct, in the performance of their duties and responsabilities, include the legal representative employees of the company, collaborators (such as consultants, representatives, intermediaries, agents, interns, etc) as well as technical and commercial partners
the principles expressed in the code of ethics represent the set of common values and essential, non-negotiable assumption that must guide the behaviors of all recipients within the scope of their functions the provisions of the code of ethics are an integral part of the contractual obligations assumed by the recipients and any violation thereof constitutes a clear breach with all legal consequences, including the possible termination of the contract or assignment and the potential compensation for damages
Specifically, pursuant to and for the purposes of articles 2104 and 2106 of the civil code, the violation of any provision of the code of ethics may result in the consistent, impartial, and uniform application of a disciplinary sanction, graduated according to the severity of the violation, in compliance with current regulations
for external collaborators and partners, adherence to the code of ethics is an essential prerequisite for establishing and continuing a professional collaborative relationship with the company
each recipient has the obbligation to:
•refrain from engaging in behaviors contrary to the provisions of the code ;
•report to the CEO and/or the general manager any information related to violations of the code ;
•collaborate with internal control structures in charge of verifying violations
•not undertake initiatives contrary to the contents of the code

the legal representative has the responsibility to:
•ensure the maximum dissemination of the code of ethics among employees and collaborators, suppliers, and partners, providing necessary interpretative support for its provisions
•develop communication actions aimed et enhancing the understanding and implementation of the code;

•conduct necessary checks regarding any reported violation of the code, including facilitating the application of necessary punitive measures by the relevant functions ;
•periodically monitor the status of the application of the code within the company

6.ETHICAL PRINCIPLES
The competitiveness of the company is closely linked to the skills of individuals and the quality of technological tools that, when integrated, are suitable for effectively achieving corporate objectives
The company is founded on the following fundamental principles:
•Legality and compliance, meaning operating in accordance with all legal provisions and in conformity with internal regulations or applicable professional standards
•Integrity, understood as correctness, honesty, loyalty and good faith in both internal and external relationships within the company Rejection of illegitimate or otherwise improper behaviors, and any from of dishonesty in order to achieve personal or business objectives;
• Equal and equal dignity, as well as impartiality in the treatment of all individuals involved in activities, without allowing any from of discrimination
•empowerment of individuals and assurance of equal opportunities for professional growth without distinction based on gender, race, language, religion, political opinions or personal and social conditions ;
•health and safety in compliance with the physical integrity, rights and dignity of workers in the workplace;
•Trasparency and professionalism with a commitment to carry out assigned tasks diligently, with clarity and appropriateness to their nature
•Fair competition in compliance with the rules and principles aimed at safeguarding free competition and promoting fair competition in the market;
•confidentiality and protection of the confidentiality of all information learned i the course of one’s work duties and adherence to contractual commitments with clients ;
•Environmental protection and respect for the communities in which operations are conducted all recipients of the code are required to adhere to the aforementioned principles Lan system will not initiate or continue any relationship with those who express a refusal to adhere to them

7.BEHAVIORAL RULES
Behavioral rules are a set of guidelines and regulations designed to illustrate and guide the expected conduct of the recipients in order to act in accordance with the mission, principles and objectives , reflecting and supporting the core values of the company
the legal representative, in full awareness of their responsibilities, unequivocally adopts the principles expressed in this code of ethics and guides their activities based on value of honesty, integrity and pursuing corporate objectives, correctness, respect for individuals and rules, intellectual honesty and mutual collaboration the commitment involves the responsible management of the company, sharing strategic-operational objectives and achieving a harmonious balance among different roles of guidance, coordination, management and control to the legal representative of the company is required :
•behavior inspire by autonomy and independence, providing accurate and timely information;
•behavior inspired by integity, loyalty, and a sense of responsibility towards the company and colleagues.
•Awareness of the role and diligent and informed participation ;
•sharing objectives and a critical spirit, in order to ensure a meaningful personal contribution
For employees and collaborators
every employee or collaborator of the company
•directs their actions towards professionalism, transparency, correctness and honesty, contributing with colleagues, superiors and collaborators to the achievement of common objectives;
•shapes their activity, regardless of the level of responsibility associated with the role , to the highest degree of efficiency, adhering to operational directives given by higher hierarchical levels;
•adapts their internal and external behaviors to the principles and values expressed in the company’s code of ethics, with an awareness of the responsibilities associated with the provision of work performance
•promotes the company’s quality policy, pursues its objectives and adopts its methods to enhance customer satisfaction throught the systematic application of processes with particular attention to processes aimed at continuous improvement and ensuring the conformity of products and services to the requirements expressed by customers;
•In interaction with colleagues, adopts behaviors guides by principles of respect, civil coexistence and full collaboration and cooperation;
•considers confidentiality of information and data as a vital principle of the activity
•uses the assets and tools provided to fully carry out their work, respecting their intended use, safety regulations, and ensuring the preservation and functionality of such assets
Compliance with laws, regulations and the applicable National collective Bargaining Agreement (CCNL) is a specific obligation for every employee. they are required to report to their immediate supervisor any violation, within the company, of laws regulations, or the code itself , with the assurance that no form of retaliation will be taken against them

Employees and collaborators are strictly prohibited from:
•the pursuit of personal interests to the detriment of the company’s interests is stictly prohibited;
•the exploitation of the name and reputation of lan system for personal purposes as well as the personal exploitation of the position held and the information acqured during the course of employment, is stictly prohibited;
•the adoption of attitudes and behaviors thet may compromise or harm the image, credibility and reputation of the company is strictly prohibites;
•the publication even throught social networks, of information and content that may be considered contrary to the mission and values defined by this code of ethics is strictly prohibited
•the use of conumable goods and company instrumental resources for purposes other than their intended ones, as well as unnecessary improper and non-rational use, is strictly prohibited ;
•the dissimination to third parties or the private or otherwise improper use of information and news concerning the company is strictly prohibited ;
•the performance of work duties, even on a voluntary basis, in conflict or competition with the company is strictly prohibited

Computer usage guidelines
regarding the use of company computer systems, including hardware, software, smartphone and tablets, whether owned by the company or third parties, it is expressly forbidden to:
•use software programs, without a license or use illegal software
•folger or alter computer documents or intercept, hinder or interrupt computer communications;
•illegaly access computer systems or any other system protected by security measures, regardless of the purpose ;

•illegally possess and use codes, password or other means suitable for accessing protected computer system, whether owned by oneself or others
•cause damage to computer systems, data, and programs owned by the company or third parties
Pertanto, attraverso il profilo dei comportamenti dovuti, i dipendenti e i collaboratori devono:
•use information, applications and equipment exlusively for work-related reasons ;
•do not lend or transfer any computer equipment to third parties without prior authorization,were required ;
• do not use accounts other than the company’s account to manage company or client data and/or information;
•avoid transfering outside the company and/or transmitting files, documents or any other confidential documentation, except for purposes strictly related to the performance of one’s duties and, in any case, with prior authorization from one’s supervisor;
•avoid leaving computer equipment provided unattended and/or accessible to others
•avoid using password of other company users, even for accessing secured areas on behalf of the same user;
•avoid using hardware and/or software tools designed to intercept, forge alter, or suppress the content of computer communications and/or documents
•use internet connection for purposes and time strictly necessary for carrying out work-related activities;
•adhere to the prescribed procedures and standards, promptly reporting to the relevant functions any abnormal use and/or functioning or information resources ;
•refrain from making copies of or downloading data, software applications, etc.
•refrain from using computer tools beyond the prescribed authorizations and, in any case, in an appropriate, resonable and respectful manner;

health,safety and environmental behavior
Business activities must be conducted in compliance with international standards, the laws and regulations of the countries in which the company operates, concerning the protection of the health and safety of workers, the environment and the communities affected by business activities
Employees must,within the scope of their duties, actively participate in the risk prevention process, environmental protection , and the safeguarding of health and safety, including the appropriate use of company assets
Operational Management of activities must, in compliance with current legislation on workplace prevention and protection, adhere to the most appropriate criteria for environmental conservation and energy efficiency, aiming to reduce their impact on the environment

8. PROTECTION OF PRIVACY, INDUSTRIAL SECRETS AND INTELLECTUAL PROPERTY
The company ensures the processing of personal and sensitive data related to its employees and third parties according to the criteria stipulated by the current privacy regulations and in compliance with confidentiality agreements with clients The company’s activities constantly require the acquisiton, storage, processing, communication and dissemination of data, documents and information related to negotiations, operations and contracts in which the company is involved
The company’s databases may also contain personal data protected by privacy regulations, which cannot be disclosed externally, and finally, data whose disclosure could cause harm to the company itself Due to their roles, the recipients are therefore obligated to safeguard the confidentiality and privacy of the information they acquire
All information, knowlwdge and data acquired processed by employees or collaborators in the course of their duties belong to the company and must be handled using measures suitable to ensure a level of security appropriate to the risk of destruction, loss, alteration, unauthorized disclosure within or outside the company

9.HARASSMENT IN THE WORKPLACE
The company works towards the empowerment of individuals by promoting socio-cultural norms that increase awarness and respect for equal opportunities. It ensures a fair and professional working environment for all employees and collaborators without distinction of gender, race, language, religion, political opinions personal and social conditions. The company condemns all forms of discrimination and harassment including unprofessional behavior, inappropriate or derogatory epithets, insults threats or mockery To this end, the company requires the commitment of everyone to adopt behaviors based on respect for others including courtesy and professionalism and to create a fair and inclusive working environment

10.WHISTLEBLOWING PROVISIONS
Confidentiality is guaranteed for those who fulfill obligations to repor crimes and/or irregularities, with full support, including legal assistance, provided by the administration this is also in compliance with the provisions of law 179/2017 on the “Provisions for the protection of authors of reports of crimes or irregularities they have become aware of in the context of a public or private employment relationship”(so called whistleblowing).

11.OBSERVANCE AND PUBLICATION
The legal representative undertakes to observe and ensure the observance of the Code of Ethics and Behavioral Rules At the Company’s headquarters, under the responsibility of the director, a hard copy of the code of ethics and Behavioral Rules is always available for consultation by the recipients

12. VIOLATION OF THE CODE OF THE ETHICS AND BEHAVIORAL RULES
It’s is the duty off all recipients to be aware of and adhere to the content of the Code of ethics and Behavioral Rules, understand their meaning, and implement them
Violation of the behavioral rules of the code of ethics by the designated individuals undermines the trust relationship established with the company and may result in the application of disciplinary sanctions proportionate to the severity of the violations

13. DISCIPLINARY AND SANCTIONING SYSTEM
In individual cases, the type and severity of sanctions applied are determined in proportion to the seriousness of the violations, taking into account the following elements :
•objectivity of the violated rules;
•intent or negligence, to be deduced, among other things, from the level of hierarchical and/or technical responsibility or from the individual’s previous work experiences and the circumstances in which the violation occurred;
•repeated instances of the conduct ;
•Involvement of multiple individuals in the violation

Sanctions for employees
the commission of offenses is sanctioned, subject to applicable legal procedures for making charges, with the following disciplinary measures
verbal warning – the verbal warning sanction should be applied in the case of a violation for minor non-compliance with the behavioral rules of the code of ethics that, not being characterized by intent or serious negligence,has not generated risks of sanctions or harm to the company written warning– the written warning sanction should be applied in cases of recurrence of the previous violation and in any case violation due to negligent non-compliance with the behavioral rules of the code of ethics that has generated potential risks for the company
fine – The fine penalty shall be applied in cases where, due to hierarchical or techinal level of responsibility of the person responsibile for the violation or other circumstances, the negligent behavior partains to the violation of a procedure thet could compromise the overall effectiveness of the code of Ethics and/or conduct standards;
Suspension from work with or without pay– the penalty of suspension from work with or without pay shall applied in case of serious and international violations that do not constitute crimes. as well as in cases of recidivism in the commission of infractions that could lead to the imposition of a fine
termination of employment –The penalty of dismissal shall be applied for serious and international violations of the code of ethics and conduct standards that constitute criminal offenses and for other violations of such gravity as to cause serious moral or material harm to the company preventing the continuation of the employment relationship even on a temporary basis, as it has undermined the trust upon which the employment relationship is based.

Penalties for freelance personnel and suppliers
The violation of the provisions contained in the code of ethics and conduct standards is sanctioned in accordance with the specific contractual clauses included in engagement letters, contracts on agreements for collaboration development. Depending on the severity of the violation, it may also result in:
•Suspension of the contractual relationship and/or related activities;
•Application of any penalties resulting from such suspension;
•Termination of the employment contract;