Art. 4 – Purpose of the Code of Ethics

This Code is intended to:

1. identify the values to which SNZ adheres in performing its activities, so as to ensure that these values represent the foundation of the Firm’s internal culture;
2. recommend, promote, or prohibit certain behaviours, over and above any legal requirements;
3. outline the ethical and behavioural principles that must be followed in the conduct of business;
4. define the rights, duties and responsibilities of SNZ towards the Recipients.

Art. 5 – General principles, values, duties, objectives and responsibilities

SNZ regards compliance with currently applicable laws, regulations and any other recognised sources of law as an essential, non negotiable principle.

In this regard, SNZ strictly adheres to the following principles of conduct:

1. It condemns and rejects any resort to unlawful or generally improper behaviour (towards the community, public authorities, clients, employees, investors and competitors) to achieve its economic objectives, which are pursued solely through excellence in performance in terms of the quality and value for money of its services, based on experience, client focus and innovation;
2. It implements organisational tools designed to prevent violations of the principles of legality, transparency, propriety and fairness by its employees and collaborators, and it oversees their observance and concrete implementation;
3. It undertakes to promote fair competition, which it considers beneficial not only to its own interests but also to those of all market participants, clients and stakeholders in general;
4. It pursues excellence and competitiveness in the market, offering its clients high quality services that efficiently meet their needs;
5. It protects and values the human resources on which it relies;
6. It uses resources responsibly, aiming at sustainable development, in respect of the environment and the rights of future generations.

Honesty and transparency represent fundamental principles for all SNZ activities and are essential elements of the Firm’s business management.

The conduct of the Recipients in carrying out their activities must therefore be based on principles of fairness, cooperation and loyalty.

SNZ commits to avoiding all forms of discrimination on the grounds of age, sex or sexual orientation, health status, ethnicity, nationality, political opinions or religious beliefs.

The processing of data collected in databases and archives is directed solely towards the achievement of professional objectives.

The Recipients are required to ensure the protection of personal data processed by SNZ and to take all necessary steps to ensure compliance with the obligations set out in the applicable data protection legislation.

SNZ acknowledges the central role of human resources and the importance of establishing and maintaining relationships based on mutual trust.

SNZ also commits to consolidating and spreading a culture of safety, raising awareness of risks and promoting responsible behaviour on the part of all Recipients, particularly with a view to safeguarding their health and safety at work, in accordance with applicable legislation.

SNZ requires that, in internal and external working relationships, no form of harassment occurs. In this regard, SNZ opposes by all available means, any form of sexual harassment, in particular any conduct that seeks to subordinate professional advancement or other benefits to the provision of sexual favours, or any private interpersonal proposals that, being unwelcome to the recipient, may disturb their peace of mind.

SNZ discourages the abuse of alcoholic or narcotic substances. In particular, each employee or collaborator of SNZ must refrain from carrying out their duties under the influence of alcohol, narcotic substances or any other substance producing similar effects, and must avoid consuming such substances during working hours; this is particularly important in cases involving the use of vehicles for professional purposes.

In order to protect individuals from the dangers of passive smoking, SNZ prohibits all Recipients from smoking within the Firm’s premises, except in any areas specifically designated and equipped in accordance with applicable law.

SNZ promotes the conduct of its activities with a focus on respect for the environment.

Art. 6 – Listening, dialogue and transparency

SNZ holds that the client must always remain the focal point of its attention, and that sustained dialogue is the only means to discern clients’ genuine expectations and preserve relationships at a superior level of excellence.

Through active dialogue with clients, the Firm accurately identifies their real needs, which constitute the essential basis for providing advice and assistance aligned with those needs, acknowledging the Firm’s pivotal role in legal representation.

The Firm believes that a lasting, trust based relationship rests on clear communication that enables the client to understand, at all times, the characteristics and added value of the services provided. SNZ also believes that the services offered must be accessible to everyone:

1. without discriminating against clients on the basis of nationality, religion or gender;
2. by tailoring its offer so that all social groups can find an adequate response to their needs;
3. by adopting a pricing policy consistent with the quality of the services offered;
4. by committing to make the Firm’s offices accessible to persons with disabilities, removing any architectural barriers.

Art. 7 – Respect for individuals

SNZ believes that respect for the personality and dignity of each employee and collaborator is the foundation for creating a working environment based on mutual trust, loyalty and enriched by everyone’s contribution:

1. by adopting recruitment and management practices based on fair and consistent behaviour, preventing favouritism, abuses and discrimination on grounds of gender, ethnicity, religion, political or trade union affiliation, language, age or different abilities;
2. by guaranteeing equal opportunities for professional development and growth, for access to training programmes and update initiatives, and for the assignment of roles;
3. by recognising to all employees and collaborators the right to express their individuality and creativity in their work and by valuing diversity and individual characteristics as a driver of innovation and an essential contribution to the Firm’s growth;
4. by paying the utmost attention to the definition of objectives, encouraging their understanding and acceptance, in order to promote correct and transparent behaviour in the relationship with clients;
5. by establishing objective and transparent incentive systems, setting feasible and achievable targets;
6. by promoting policies that facilitate the balance between personal and professional life, supporting flexible working arrangements and implementing initiatives to reconcile work and private commitments, recognising that the private sphere constitutes a fundamental part of everyone’s life

Art. 8 – Conflict of interest

In accordance with the Italian Code of Professional Ethics for Lawyers, the Firm guarantees full compliance with the rules designed to prevent possible conflicts of interest, and in particular with Article 24 thereof:

“The lawyer must refrain from performing professional activities when these may create a conflict of interest with the interests of the represented party or the client, or interfere with the performance of another mandate, even when non professional.

In performing professional duties, the lawyer must maintain independence and protect freedom from any form of pressure or undue influence, including those arising from personal interests.

A conflict of interest also exists where the assumption of a new mandate would breach the duty of confidentiality regarding information provided by another represented party or client, the knowledge of one party’s affairs would unfairly benefit another party or client, or the performance of an earlier mandate would limit the lawyer’s independence in carrying out the new assignment.

The lawyer must notify the represented party and the client of any circumstances that impede the requested service. The duty to abstain also applies when the conflicting parties are represented by lawyers who are partners in the same firm or professional association, or who practise from the same premises and engage in regular professional collaboration. ”.

Art. 9 – Duties of employees and collaborators

Employees and collaborators must act loyally and in good faith in order to comply with the obligations set out in their employment agreements and in this Code of Ethics, performing the services required.

Employees and collaborators must be familiar with, and implement, the Firm’s policies on information security, thereby ensuring the integrity, confidentiality and availability of information.

They are required to prepare their documents using clear, objective and comprehensive language, so as to allow any necessary review by colleagues, supervisors or authorised external parties.

All employees and collaborators are required to avoid situations in which conflicts of interest may arise and to refrain from taking personal advantage of business opportunities of which they become aware in the course of their duties.

Art. 10 – Duties of consultants, suppliers and SNZ Partners

The management of relationships with consultants, suppliers, Partners and any parties who, directly or indirectly, permanently or temporarily act on behalf of or in the interest of SNZ under specific contracts or agreements shall be governed by the principles of impartiality and fair competition.

SNZ requires that the selection of such parties be made exclusively on the basis of objective evaluations of their professional qualifications and capabilities relative to the services required. Procurement procedures are designed to secure the Firm’s best competitive outcome while ensuring equal opportunities for all suppliers and are conducted with mutual fairness, transparency and cooperation at both pre contractual and contractual stages.

Art. 11 – Gifts, promotional items and benefits

No form of gift is permitted if it could even be perceived as exceeding normal business practices or customary courtesies.
In particular, any form of gift to Italian or foreign public officials or their family members that might influence their independence of judgment or induce them to confer any advantage is strictly prohibited.
Any promotional items or gifts issued by SNZ must be aimed at promoting the Firm’s brand image.

Art. 12 – Environmental policy

The protection of the environment is one of the key dimensions of the Firm’s commitment.
A central aspect of its social responsibility policy is the rejection of waste and careful attention to the environmental impact of its choices.
SNZ believes that it can make a significant contribution to environmental sustainability, particularly within the social and environmental context in which it operates, both in the short and long term.
Such impact includes both the direct consumption of resources and the generation of emissions and waste directly linked to its activities (“direct impacts”), and activities and behaviours carried out by third parties with whom the Firm interacts, such as clients and suppliers, over which SNZ does not have direct control (“indirect impacts”).
Within this framework, the Firm pursues the conscious use of the resources necessary for its operations, also through the implementation of an environmental management system and the progressive improvement of the energy efficiency of its activities.

Art. 13 – Implementation of the Code of Ethics

The responsibility for monitoring the effectiveness and enforcement of the Code of Ethics is entrusted to the Firm’s current legal representative.

All Recipients are required to cooperate with the current legal representative and to provide any documentation necessary for the performance of their duties.

Reports of any unlawful acts or violations of this Code of Ethics and of the related procedures by the Recipients may be submitted in writing or orally to the Firm’s current legal representative.

Art. 14 – Dissemination of the Code of Ethics

The Code of Ethics is adopted by the Firm’s Sole Director.

SNZ shall notify all Recipients of the adoption of the Code by appropriate means and shall inform them that the Code is available for consultation on the Firm’s official website.

SNZ undertakes to incorporate a provision referring to this Code of Ethics into the contracts and agreements executed by the Firm, thereby informing contracting parties of the Code’s existence, its binding nature and the consequences of non compliance.

The Sole Director shall ensure the periodic review and updating of the Code of Ethics to align it with legislative developments, changing environmental conditions, evolving social sensibilities, and in response to reports from interested parties and experience gained from its application.

Art. 15 – Disciplinary system and sanctions

In the event of breaches of this Code, the Firm shall implement appropriate measures. Where the conduct in question does not amount to fraud or breach specific legal, contractual or regulatory provisions, SNZ shall adopt a constructive approach, which may include targeted training interventions, with the aim of strengthening individuals’ awareness of and adherence to the values and principles set forth in the Code.