1. INTRODUCTION
Since 1981, New Line RdM has built its reputation on integrity and respect for all parties directly and indirectly affected by its activities. Reputation is a crucial asset, just like people, work capacity and the corporate brand. Our priority is to remain in a successful business, fostering growth, balancing medium- and long-term interests and ensuring that future generations have the same opportunities we received from our predecessors. This means taking care of our clients, families, partners and more broadly, our world. Success requires high standards of behavior from everyone. We want this Code of Conduct to be more than just a list of principles—it should serve as a reference for our daily professional lives.
2. PRINCIPLES OF CONDUCT
We are committed to conducting our work with honesty, integrity, open-mindedness, confidentiality and respect for human rights, particularly the rights of our colleagues and all those directly involved in our activities. We aim to adopt a problem-solving approach in every situation.
3. COMPLIANCE WITH THE LAW
New Line RdM and all individuals acting on its behalf commit to operating in full compliance with laws and regulations.
4. ETHICAL STANDARDS
Our work must adhere to the following principles:
Loyalty and Good Faith: Always act with loyalty and good faith towards the company, supervisors, colleagues and business partners.
Conflict of Interest: Prioritize the interests of New Line RdM over personal or third-party interests that could influence decisions, behaviors, services, or consulting activities when acting on behalf of the company.
Use of Information: Information must be handled and communicated comprehensively, accurately, promptly and truthfully. It must not be used or disclosed for personal or third-party advantage. Confidentiality, integrity and completeness of information must be safeguarded.
Respect and Listening: Show respect and listen to others’ perspectives, particularly in professional relationships and interactions with colleagues.
Innovation: Promote continuous improvement and innovation to achieve the highest quality while considering profitability and corporate value.
Relationships with Suppliers: Treat suppliers fairly and in full compliance with legal obligations. It is strictly prohibited to offer, give, solicit, or receive any compensation or remuneration outside of contractual agreements.
Customer Orientation: Operate with effectiveness, professionalism and collaboration, fully meeting clients’ needs and expectations through high-quality, competitive solutions. Maintain a courteous and helpful attitude and consult a supervisor in challenging situations. It is strictly forbidden to solicit or accept compensation from New Line RdM clients for any internal or external activities.
Industry Events and Trade Shows: Employees are encouraged to attend and support industry events and trade shows as a means of professional growth and team-building.
5. ANTI-CORRUPTION PRINCIPLES
All recipients of this Code must comply with anti-corruption laws (ref. Legislative Decree 231/2001, Italian Penal Code Articles 317 and following, Italian Civil Code Articles 2635 and 2635-bis) and uphold the principles of legality, transparency, ethical management and zero tolerance for corruption.
Anti-corruption regulations prohibit payments, offers, promises, or authorizations of payment or value transfers, directly or indirectly, to any public official or third party, knowing that such payments or benefits will be transferred to a public official.
Bribery in commercial transactions, including payments or benefits offered directly or indirectly to any private party to unlawfully obtain or retain business or economic advantages.
Situations at risk of corruption gifts, Invitations and Hospitality Expenses: While gifts and invitations can foster good relationships, they can also be perceived as an attempt to influence decisions.
Donations and Sponsorships: These should be made for legitimate purposes, such as research, education, environmental sustainability, or charitable activities.
Hiring and Professional Engagements: The selection of personnel and professionals must be based on fairness, impartiality, transparency and competence.
All employees must report suspected corruption risks to their manager or HR. Reports made in good faith will be protected against retaliation and handled confidentially, in accordance with applicable regulations.
6. WHISTLEBLOWING REPORTS
The company has implemented a reporting system in accordance with the provisions of the Whistleblowing Decree and complies with personal data protection regulations, particularly with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, dated April 27, 2016, concerning the protection of natural persons with regard to the processing of personal data.
For details, please refer to the specific procedure attached to the Code of Ethics (ALL_Procedura Whistleblowing), which aims to illustrate the process for reporting unlawful conduct within the corporate context, specifically:
- identify individuals who may submit reports;
- define the scope of behaviors, events, or actions that may be the subject of reporting;
- identify the channels through which reports can be made;
- outline the operational methods for submitting and managing reports, as well as any consequent verification activities;
- inform the whistleblower and the reported person about the forms of protection that are recognized and guaranteed.
7. STAFF CONDUCT
All company staff working on behalf of New Line RdM must demonstrate a high level of professionalism:
Competence: Ensure that both individual and team skills remain up-to-date to achieve the best possible performance in executing their duties.
Efficiency: Strive to meet set objectives for their responsibilities in the most efficient and productive manner possible.
Cooperation: Actively and personally cooperate with company units and departments, colleagues and other employees.
Workplace Risk Prevention: Everyone is responsible for their own health and safety as well as that of others. All personnel must comply with health and safety prevention measures, using appropriate individual and collective protective equipment. Managers must supervise team members.
Zero Alcohol Policy: At all times during work activities, refrain from consuming alcoholic beverages (wine, beer, spirits, etc.) that could affect job performance, both before starting work and during breaks. This is particularly crucial during business trips that involve driving a vehicle (whether personal or company-owned). The consumption of alcohol is prohibited for an appropriate period before driving and for the entire duration of the journey.
Dress Code: Maintain an appearance consistent with the company’s image, ensuring cleanliness and appropriateness.
Managers: Team leaders must focus on the motivation, development and professional satisfaction of their team members, providing growth opportunities based on merit and individual professional contributions. This includes promoting training and learning, specifically recognizing efforts and objectively evaluating results.
Environmental Respect: Actively and responsibly contribute to environmental conservation, not only by complying with legal obligations but also by participating in environmental programs endorsed by New Line RdM and diligently identifying and correcting behaviors that could harm the environment.
Availability: Dedicate the necessary effort to perform job functions and be open to potential schedule flexibility required by the market.
Desks and Screens: Maintain clean desks and screens. Ensure that confidential information is not left unattended and accessible. For example, avoid leaving worksheets on desks or discarding them without destruction. Screens should be positioned to prevent unauthorized viewing of information.
Work Environment: Maintain personal workspaces and common areas, including the cafeteria and meeting rooms, in an orderly and clean state. Notes, bottles, glasses and food remnants must be cleared by the users themselves.
8. USE OF COMPANY ASSETS
IT Equipment: The use and management of IT assets are governed by the IT Tools Regulation, ensuring proper handling and security of all digital resources.
Company Vehicles: Vehicles provided for business purposes are assigned to a designated employee, who is responsible for maintaining their efficiency by adhering to scheduled maintenance. Vehicles must be used with caution, prioritizing safety and compliance with traffic laws, corporate policies and environmental considerations. Special attention should also be given to securing transported goods.
Fines incurred while driving company-registered vehicles will be charged to the employee behind the wheel at the time of the infraction. In cases of clearly reckless or negligent behavior and/or resulting damage to a company vehicle, disciplinary and financial penalties may apply.
9. REMOTE WORKING
The execution methods are outlined in the internal document NL RdM Flex.
10. TERMINATION OR ROLE CHANGES
Responsibilities and duties related to information security remain valid after the termination or change of the employment relationship.
In particular, the HR department, during the employee’s departure or role change, will complete a checklist (see the file check list dimissioni cambio ruolo V01.xls) to verify that all company-issued items are returned and will request the signing of a self-declaration in which the departing employee confirms that they are not taking any company information or data with them.
11. ACCESS TO COMPANY FACILITIES
Access to the facilities must follow the established rules: guests must be registered and access-restricted areas must be respected by everyone.
12. KNOW-HOW AND CONFIDENTIALITY
Employees of New Line RdM perform their professional duties, both within the Company and in relations with third parties, always ensuring the absolute confidentiality of information whose disclosure or publication could affect the interests of the parties involved.
This principle, which remains valid even after the termination of the employment relationship with New Line RdM, is realized through compliance with the following rules:
Professional Secrecy: Professional secrecy must be maintained regarding data, reports, accounts, statements, strategic plans and other activities of New Line RdM and its personnel that are not publicly available and whose disclosure could affect the interests of New Line RdM. It is prohibited to disclose such information without authorization unless acting in accordance with a specific judicial request or a legal provision.
Intellectual Property: It is prohibited to use, for personal or third-party purposes or for profit, programs, IT systems, manuals, videos, courses, studies, reports, etc., created, developed, or refined at New Line RdM, as the Company always retains intellectual property rights over them.
Knowledge and Know-How: All knowledge developed in the course of activities carried out for New Line RdM must be considered first and foremost as the property of New Line RdM. The use of such knowledge outside of this context must adhere to principles of confidentiality and fairness.
When appropriate, New Line signs specific documents related to the DPS of clients (Security Programmatic Document). All employees of New Line RdM are required to observe this commitment, following principles of discretion and confidentiality.
13. GENERAL RESTRICTIONS AND INCOMPATIBILITIES
Employees of New Line RdM may not hold positions, perform functions, or act on behalf of competing companies, suppliers of goods and services, or companies that exercise any form of dominance or control over competing companies.
Employees are required to consult New Line RdM before accepting any position, co-option, or appointment outside the Company that may affect their independence and professional dedication to the Company.
14. DISCIPLINARY ACTIONS
Failure to comply with the rules set out in this Code of Conduct may lead the Human Resources Department to take disciplinary measures appropriate to the severity of the incident, unless more severe civil or criminal penalties are provided for by law.
The disciplinary rules concerning sanctions, infractions and dispute procedures are contained in the Civil Code, in Law 300/1970, Article 7 and in the current National Collective Labor Agreement (C.C.N.L.) for Commerce and its subsequent amendments, both with regard to the regulatory and economic aspects. The applicable Provincial Supplementary Contract is also considered, for the points where it remains valid.
15. OVERSIGHT AND INTERPRETATION
The interpretation of this Code of Conduct is the responsibility of the Company’s Board of Directors. Any requests for opinions and authorizations mentioned in this document must be addressed to the Company’s Human Resources Department. Furthermore, any non-compliance must be reported to this Department, which is responsible for providing instructions regarding the application of this Code of Conduct.