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Rev. 01 dated 12/15/2021, Revision with inclusion of paragraphs 4.8-4.9-4.10-4.11-4.12 and Chapter 7.
Rev. 00 dated 14.04.2014, First issue



Sintagma, which has always been committed to strict adherence to reference principles in the performance of its activities, in order to pursue, in an effective manner, the goal of continuous improvement in the context of its Corporate Social Responsibility, has seen fit to adopt and issue this Code of Ethics. This document makes explicit the aforementioned reference corporate principles and values and the modes of behavior derived from them.
The actions and behavior of all Recipients of this Code of Ethics (see appropriate section) must refer to these principles and standards, both in internal professional relations and in relations with parties external to Sintagma.
Ethics defines, in fact, a set of rules of conduct to be followed by one or more persons. It is the result of deep reflection on rules and principles to be followed in daily activities. The scope of ethics is, therefore, not on a theoretical level, but on a practical one.
The Code of Ethics sets out lines of conduct aimed at making the actions (practices) of the people associated with Sintagma oriented towards the requirements of Corporate Social Responsibility (orthopraxis), i.e. the ability to harmoniously integrate its business activities with respect for and protection of the interests of all parties affected by them, including future generations (e.g. by means of environmental protection).
The CEO of Sintagma approved this Code of Ethics on 12/15/2021.


Sintagma recognizes Social Responsibility as essential in the conduct of business and corporate activities. Accordingly, SINTAGMA is committed to simultaneous respect for the legitimate interests of Shareholders, Directors, Employees, Collaborators, Customers, Suppliers and Partners.
To this end, it is committed to:

  • Pursue ethically sound and economically, financially, socially and environmentally sustainable corporate values based on a relationship of trust with Customers, motivation of Collaborators and Employees, and marked by a synergistic relationship with Partners and Suppliers;
  • Harmoniously promote the personal and professional development of its Employees and Collaborators, motivating them to a sense of belonging to the Company and the systematic pursuit of continuous improvement in the efficiency and effectiveness of their actions and the Company's actions, in order to increase the overall personal satisfaction and well-being of all Interested Parties;
  • Maintain deep consistency with its longstanding policies on transparency, loyalty, fairness, reliability, trust and cooperation in conducting business;
  • act to continuously improve the quality of goods and services offered to Customers, aiming at the growth of their satisfaction while constantly remaining in full, absolute and unwavering compliance with applicable laws and regulations;
  • increasingly develop an active role with respect to the market, economic development and technological and scientific progress;
  • Raising awareness and involvement of Suppliers and Partners by making them participatory and proactive, especially with regard to compliance with laws and regulations related to the provision of goods and services and with regard to transparency and communication to Customers.

In view of these commitments, Sintagma requires all its Employees and all those who cooperate with it (Collaborators, Suppliers, Partners), to scrupulously and continuously comply with the company rules and the provisions established in this Code of Ethics.
The achievement of these commitments can, in fact, take place only through the continuous, constant and active participation of all Parties Interested in and/or involved by Sintagma's business activities and the full awareness, on their part, that these goals must be achieved in compliance with those reference values and rules of conduct that this Code of Ethics makes explicit.
The provisions contained in this Code of Ethics and the principles of conduct set forth in it must not appear to the Recipients as "obvious" and/or "taken for granted," but must be the cue for a reflection on the values referred to in them. From such reflection must flow an awareness of their structural necessity within the Company. If personal adherence to these values also flows from such deepening, this contributes greatly to spontaneous compliance on the part of each Recipient.
Sintagma, in particular, is committed to:

  • keep the Code of Ethics constantly updated
  • Promote maximum dissemination and awareness of the Code of Ethics
  • Systematically interpret and implement the provisions of the Code of Ethics
  • Objectively assess the facts and apply appropriate sanctions in case of violation of the Code of Ethics.


The norms and reference values contained in this Code of Ethics are binding for the entire Sintagma and therefore for Shareholders, Directors, Managing Director, Employees and Third Parties who in any capacity operate in the interest of the Company; including, therefore, also Suppliers, Partners, Consultants and Collaborators in any capacity. All these persons will be hereafter, more briefly, referred to as "Collaborators."
The Shareholders and Directors, in particular, are required to be inspired by these values and rules of conduct in setting the Company's objectives and strategies, in proposing investments, in implementing projects, as well as in any decision and/or action regarding the management of Sintagma.
II Employees all are required to comply, in the performance of their functions and responsibilities, with the principles and rules of conduct contained in this Code of Ethics, procedures, regulations and company policies.
The Employees All are, moreover, called upon to require everyone to comply with the principles and rules contained in this Code of Ethics. This means that such compliance will also be demanded of them by independent third-party Collaborators who, in any capacity, work in the interest of the company. In this context, Employees undertake to make such Third Party Collaborators aware of the contents of this Code of Ethics and to instruct and sensitize them to respect the rules and principles contained herein.
The Company's Collaborators are therefore obliged to adapt their behavior to the provisions of the Code of Ethics, procedures and company regulations.
The Recipients, if Employees of Sintagma, undertake to:

  • Maintain an up-to-date knowledge of the Code of Ethics and the relevant standards governing their activities;
  • Not to engage in behavior contrary to the principles and standards expressed in the Code of Ethics;
  • contact their supervisor to obtain clarification, should it be necessary, for the application of the Code of Ethics;
  • Promptly report to their supervisor, any violation of the Code of Ethics that they have encountered or any request for its violation that has been addressed to them;
  • Cooperate with corporate functions, for investigation and verification regarding actual or potential violations of the Code of Ethics;
  • adequately inform third parties of the obligations imposed by the Code of Ethics and demand compliance;
  • Act proactively and promptly to counter the failure of third parties to comply with the requirements of the Code of Ethics.

Recipients who hold positions of responsibility within one or more corporate functions have the following additional obligations:

  • To hold exemplary behavior on the subject of the Code of Ethics;
  • operate with extreme care the selection of employees and external collaborators to entrust them with assignments, binding them to punctilious compliance with the rules contained in the Code of Ethics;
  • operate popularization and empowerment actions for its subordinates so that they become aware of the importance of the Code of Ethics and abide by the rules contained therein;
  • Have its subordinates observe the rules of the Code of Ethics;
  • Promptly report to their supervisor in cases of violation or attempted violation of the Code of Ethics;
  • Immediately take the required corrective actions in the face of the above violations or attempted violations;
  • Protect the confidentiality of the reporter;
  • Be vigilant and work to prevent any kind of retaliation against the whistleblower.


4.1 Privacy Protection

Sintagma recognizes as an unwaivable principle compliance with the laws and regulations in force.
The Shareholders, Directors, Managing Director, Employees and Collaborators who in different capacities are involved in the business activities, are required to operate in the Company and on behalf of the Company in total transparency and absolute compliance with the mandatory laws and regulations.
Accordingly, they undertake to have and keep constantly up-to-date the best possible knowledge of the applicable regulations relating to their activities and the responsibilities arising from the violation thereof.
Under no circumstances, not even in the pursuit of a legitimate interest of the Company, can any action that does not comply with the aforementioned laws and regulations be justified.

4.2 Centrality of the person

Sintagma places the Person at the center of its work.
Consequently, it promotes respect for the physical, moral and cultural integrity of each person, guaranteeing, in addition, working conditions that respect individual dignity and safe working environments.
All recipients of this Code of Ethics are called upon to value listening and dialogue as levers for improvement.
Listening and Dialogue should also be the continuous stimulus for the search for solutions to be proposed not only in relations with customers, but also in relations with their collaborators and colleagues with the utmost respect for the professionalism and competence of each.

4.3 Integrity

Since moral integrity is a constant duty of all those who work in the name of and/or on behalf of Sintagma, all Recipients of this Code of Ethics are required to pursue their work objectives with honesty, fairness and responsibility and to maintain a conduct marked by punctual and constant compliance with the rules, laws and professional ethics.

4.4 Equity and equal opportunity

Sintagma is committed to avoiding any discrimination in personal conduct and to respect differences in gender, age, race, religion, political or union affiliation, language, culture or different abilities.
All recipients of this Code of Ethics are called to operate taking into account the concrete circumstances, avoiding discriminatory and opportunistic behavior and contributing to the emergence and development of the potential of each person.

4.5 Efficiency in work activity

Sintagma provides design and delivers technologically advanced services through its specialized expertise and organizational capacity.
All services must be designed and implemented according to the methodological standards required by quality/safety/environmental/corruption prevention regulations and the current Integrated Management System. Guiding criterion of this design is the satisfaction of the needs of the Interested Parties.
All services sold shall follow similar principles regarding Interested Party satisfaction.
All recipients of this Code of Ethics are called upon to comply with existing management procedures and to cooperate proactively in the continuous improvement mechanism inherent in the Integrated Management System, striving to achieve objectives of increasing efficiency in the provision of goods and/or services to Customers.

4.6 Transparency and completeness of information

Sintagma promotes transparency in communications, in formal agreements and in the criteria underlying the behaviors followed in order to allow correct and conscious autonomous choices by the subjects involved.
All Recipients of this Code of Ethics are called, therefore, to respect the principles of:

  • truthfulness,
  • correctness,
  • thoroughness,
  • accuracy,
  • transparency.

regarding any information and/or communication.
All Recipients are, in addition, required to communicate clearly and diligently the corporate image in all its internal and external relations.

4.7 Safeguarding the Environment

SINTAGMA's commitment to the environment is aimed at its overall preservation, recognizing it as a finite resource to be protected so that future generations can also enjoy it. Sintagma is committed to applying, towards the environment, the criterion of "maximum precaution" and to favor preventive approaches to minimize the environmental impact of its activities as evidenced by the ISO14001-compliant Environmental Management System.
All addressees of this Code of Ethics are called upon to operate with environmental protection issues in mind, with particular attention to the issues of fighting pollution and saving energy and material resources.

4.8 Job Security

SINTAGMA ensures that employees, collaborators, and partners work in working conditions that respect individual dignity and in safe and healthy working environments, in full compliance with current national and international regulations on the protection of health and safety in the workplace.

4.9 Confidentiality

In accordance with the provisions of the law, SINTAGMA ensures the confidentiality of information in its possession and concerning all stakeholders (employees, customers, suppliers, etc.).
Any information may be provided to third parties only in full compliance with the regulations in force, or according to precise and specific agreements between the parties. All persons acting in the name and on behalf of the Organization are prohibited from using confidential information for purposes unrelated to the performance of their assigned professional duties.

4.10 Conflicts of Interest

In carrying out any activity, SINTAGMA is committed to avoiding any situation of conflict of interest, real or potential.

4.11 Free and fair competition

SINTAGMA recognizes that fair, free and fair competition is a decisive factor for growth and constant improvement for businesses and the market and, therefore, the fundamental principles that guide its operations include fair competition with competitors.

4.12 Condemnation of any form of corruption

SINTAGMA respects and requires compliance with current legislation on preventing and combating corruption from all persons acting on its behalf. It absolutely prohibits conduct that may amount to bribery or attempted bribery or inducement to bribery.


5.1 Human Resources Management

In compliance with the values stated above, Sintagma recognizes human resources as an indispensable element for successfully carrying out its activities and achieving the company's objectives. It also recognizes the importance of establishing relationships with them based on the principles of loyalty, respect and mutual trust.
The Company undertakes to ensure that the selection, grading and career path of company personnel respond, exclusively, without any discrimination, to objective considerations of the professional and personal characteristics of each person and necessary for the performance of the task to be carried out and the abilities demonstrated in the performance of the work activity.
The Recipients of this Code are required to reject any discriminatory behavior put in place with regard to access to employment, the assignment of qualifications and duties, career progression, or the assignment of positions.
In particular, the following are strictly forbidden: the hiring, even as mere collaborators, of foreign persons without a regular residence permit; the hiring, even as mere collaborators, of minors of non-working age; the failure to respect basic union principles resulting in the subjection of personnel, even as mere collaborators, to particularly onerous and/or degrading conditions.

5.1.1 Resource selection and management

Based on the above considerations, the company's policies for the selection, remuneration and training of Employees and Collaborators must be guided by criteria of professionalism, seriousness, competence and merit.
In particular, the functions in charge must ensure that:

  • the resources acquired correspond to the profiles really needed for the company's needs, making every effort to avoid favoritism and facilitation of any kind, respecting equal opportunity and without any discrimination on the basis of considerations relating to the private sphere and personal opinions of the candidates;
  • the acquired resources, if foreign, are in compliance with any applicable residence permit regulations, are of working age, and are not subjected to degrading working conditions;
  • fair treatment and equal opportunities in the allocation of roles or assignments are guaranteed to each person considering also the fact that mobility to different job positions can be an element to foster professional growth;
  • fair and consistent behavior is maintained toward Employees and Collaborators, preventing favoritism, abuse and discrimination based on sex, race, religion, political and union affiliation, language, culture, age, different ability or other criteria.

5.1.2 Professional development and resource training

Sintagma believes that the professional growth and enhancement of its human resources is fundamental. It undertakes, therefore, to contribute to this by offering them, periodically, opportunities both for mutual knowledge and information of their respective work experiences, and for training interventions, in order to promote their growth and allow them to develop their professional skills within the company.
Consequently, Executives and Managers are called upon to pay the utmost attention to enhancing and increasing the professionalism of their colleagues and Collaborators by creating the conditions for the development of their abilities and the realization of their potential.
In particular, the functions in charge must ensure that:

  • the necessary conditions are created and maintained to develop everyone's skills, abilities and talents while respecting equal opportunities (gender, race, ...);
  • systems are used to evaluate each person's behavior, skills, knowledge and potential according to criteria of transparency and meritocracy;
  • everyone is given the opportunity to express their individuality in their work, valuing each person's diversity and specificity;
  • conditions are maintained that enable everyone to best interpret his or her role by fostering constant improvement in the level of competence and developing the ability to work as a team to contribute to the achievement of company goals;
  • training that also takes into account individual needs is proposed, evaluated and developed when designing training paths.

5.1.3 Working Environment

All Employees and Collaborators must be treated in strict compliance with the principles set forth in this Code of Ethics and within a climate that favors communication and cooperation to the maximum, among themselves and with superiors and subordinates, with a view to a common and shared goal of growth and consolidation of the spirit of belonging to the company.
In particular, Top Management, Managers, Employees and Collaborators who work in different capacities on behalf of and/or in the name of Sintagma must:

  • To base their interpersonal and professional relationships on criteria and behaviors of fairness, loyalty and mutual respect;
  • To promote and support respect for the personality of each colleague and Collaborator as a fundamental element in the development of a work environment permeated by mutual trust and the contribution of each individual;
  • Commit to creating a work environment that guarantees, for all those who in any capacity interact with Sintagma, conditions that respect personal dignity and in which the characteristics of individuals cannot give rise to discrimination or conditioning;
  • strive to create a work environment that is always stimulating and rewarding and thus fosters the development of everyone's potential.

Sintagma is committed to prosecuting any type of harassment in the workplace. Specifically, harassment is defined as (but not limited to):

  • The establishment of a hostile, intimidating, isolating work environment towards individuals and/or groups of people;
  • Unwarranted interference in the performance of the work of others;
  • conduct of any kind that may be harmful to the dignity and/or personal and/or sexual freedom of workers.

5.2 External Communication

Relations with the outside of Sintagma, in particular with Customers, Suppliers and the mass-media, must be maintained only by the company functions appointed for that purpose and according to the appropriate communication procedures.
No Recipient of this Code of Ethics may provide information to persons outside the company, in particular to Customers, Suppliers and representatives of the mass-media, without the explicit authorization of the corporate functions in charge.
In any case, without exception, Sintagma-related communications and information intended for outside the Company must always be complete:

  • accurate,
  • truthful,
  • complete,
  • transparent,
  • consistent

The participation of the Recipients of this Code of Ethics in external events such as, for example, meetings, meetings, seminars, conventions and the like, must always and only take place in an exclusively personal capacity, unless one is expressly authorized by Sintagma to represent it in such situations.

5.3 Financial Administrative and Accounting Management

The strictest accounting transparency is a constant priority requirement of the Company, in all cases and at all times.
Accordingly, the procurement and disbursement of financial resources, their administration and control, must always comply with the approval and authorization procedures prepared.
Shareholders, Directors, Employees, External Collaborators and all those who have any kind of relationship with the Company must behave strictly correctly, transparently and cooperatively in compliance with the law and company procedures in all activities aimed at the formation of the financial statements and other company communications.
In particular:

  • Everyone is required to strictly adhere to the prescribed procedures and to cooperate to the fullest extent possible so that management facts are correctly and comprehensively presented and promptly reported in the company's accounts;
  • each person, within the scope of his or her competencies and functions, must adhere to the strictest principles of transparency, correctness and truthfulness in the preparation of accounting documents and data, as well as any records pertaining to the administration also in a general sense;
  • in the case of economic/asset items based on valuations and estimates, the relevant entry must be made by clearly explaining, in the specially prepared documentation, the criteria that led to the determination of the value of the asset in question;
  • Documentation to support each accounting transaction:
    • must be complete, adequate, truthful, clear and understandable;
    • must be kept on file in such a way as to allow, at any time and to any person, even external to the Company, as long as authorized, the control of the characteristics of the operation, the reasons that originated it and the precise identification of who, with what role, at the different stages, authorized, carried out, recorded, verified or performed any other activity strictly inherent to the accounting operation itself (e.g.: updating, correction, destruction, encryption, ...);
  • responsibilities regarding the management of documentation supporting each accounting operation must be clearly defined and known within the organization;
  • each accounting entry must clearly, completely and truthfully reflect what is described in the supporting and justifying documentation;
  • every financial movement must be justified, in a correct, complete and transparent manner, by an economic event related to Sintagma. Financial and/or accounting transactions that do not have a direct and explicit justification in Sintagma's activities are not permitted;
  • supporting documentation must be easily retrievable and archived according to appropriate criteria that allow it to be quickly retrieved and easily consulted by both internal and external entities empowered to audit.

5.4 Privacy Protection

In compliance with the legislation in force, Sintagma is committed to guaranteeing the protection of the rights envisaged regarding the processing of personal data, in particular regarding information pertaining to the private sphere and opinions of each of its Employees and those who interact with the Company.
It is required of Employees and Collaborators who act in the name or on behalf of Sintagma to process personal data in absolute compliance with current privacy protection legislation, according to the directives given to them.
In particular, it is made imperative to:

  • Acquire and process only the data necessary and directly related to its functions;
  • Respect the confidential and confidential nature of the information;
  • Acquire and process data for specified, explicit and legitimate purposes;
  • Acquire and process data that are relevant, accurate, complete and not excessive in relation to the purposes for which they were collected and subsequently processed, ensuring that they are kept up to date;
  • Store and use said data in such a way as to prevent outsiders from gaining knowledge of it;
  • Communicate and disclose data only within the framework of established procedures or with the prior authorization of the persons in charge;
  • keep the data in a form that allows identification of the data subject for no longer than is necessary for the purposes for which it was collected and subsequently processed;
  • Adequately inform the owners of the processed personal data about the manner, purpose, and whether or not the processing is mandatory.

The Recipients of this Code of Ethics who are also in charge of the processing of personal data, must take all appropriate measures to avoid the risks of destruction or loss, even accidental, of the said data, unauthorized access to them or processing that is not permitted or does not conform to the purposes of collection; these measures are identified and periodically updated within Sintagma within the Programmatic Security Document and other documentation on the subject.

5.5 Protection of Safety in the Workplace

SINTAGMA's primary objectives are to maintain the highest levels of hygiene, health and safety protection and to ensure the necessary preventive measures against accidents and diseases in the workplace.
In particular, SINTAGMA intends to emphasize the importance of observing the following principles:

  • the management of risks related to occupational health and safety should be based primarily on their prevention, including detailed provision for their management in the event of failure of preventive or emergency systems;
  • although the assessment of risks rests in a non-derogable manner with the Employer, the assessment of risks carried out by those working in the field is an aspect that should absolutely not be neglected as it can lead to a more realistic view of them and the adoption of more effective countermeasures. All Recipients of this Code of Ethics are therefore required to give serious consideration to all reports made by their colleagues, subordinates or collaborators in the broadest sense, including Customers and Suppliers.

Each Recipient must actively contribute to maintaining the work environment in which he or she works healthy and safe and ensure the safety of his or her own Colleagues, Collaborators and third parties who are in any case exposed in the area of activity and/or in neighboring areas.
All Recipients are also required to manage risks in a preventive manner, following the appropriate procedures and using, where provided, personal protective equipment.
Upon the occurrence of a hazardous situation, even if it has not led to personal injury or property damage, it must be reported immediately to one's supervisor so that it can be made known to the RSPP in order to assess whether further countermeasures to protect health and safety are necessary or whether those already in place are sufficient.

5.6 Protection of Intellectual Property Rights

SINTAGMA recognizes intellectual property as an intangible asset worthy of respect. To this end, it considers punctilious compliance with the relevant legal provisions to be indispensable.
For this reason, all Recipients of this Code of Ethics, within the scope of the activities inherent to the Company, are bound to such respect and, in particular:

  • To use only properly licensed software and databases;
  • to use texts, technical standards, and information services, regardless of the medium in which they are used, only if they are original and in compliance with the aforementioned Intellectual Property regulations;
  • not to disassemble, reverse-engineer, or perform similar activities on hardware and software products, machinery, installations, or any other assets, tangible or otherwise, that may be covered by intellectual property rights, except as permitted by law;
  • Not to reproduce, in whole or in part, store, exchange or disseminate, without express authorization or outside the cases provided by law, texts, designs and other intellectual property rights-covered products.

5.7 Protection of Corporate Assets

Each corporate function must make every effort to be fully aware at all times, for the area of its responsibility, of the rights and obligations incumbent on the Company arising from legal regulations, contracts or relations with the Public Administration, and must not engage in any behavior that could harm, in any way, the interests of the Company. This knowledge must be promptly and clearly transmitted, by each corporate function, to its collaborators, in the appropriate form and content, in order to make all Interested Parties (including Customers and Suppliers) aware of the above obligations and guide them in the necessary fulfillment. Each corporate function shall then supervise compliance with these obligations with respect to its collaborators and Interested Parties for whom it is responsible or with whom it interfaces.
All Employees and Collaborators working on behalf of or in the name of Sintagma are absolutely forbidden to disclose to third parties information not known to the public regarding projects, acquisitions, mergers, business strategies and, more generally, non-public information regarding the company of which they have become aware or whose disclosure could, in any case, be detrimental to the interests of the company.
Each Recipient of this Code is responsible for guarding, preserving and defending the company assets and resources entrusted to him/her within the scope of his/her activity and is obliged to use them in his/her own and compliant manner, preventing any improper use. Prior to the use of any company asset, Recipients are required to ascertain, to the best of their ability, its proper and safe state of operation.

5.8 Protection of Social Assets

In order to protect the integrity of the company's assets, it is particularly prohibited, outside the cases permitted by law, to:

  • Return contributions in any form or release members from the obligation to make them;
  • distribute profits not actually earned or allocated by law to reserves, or to reserves that are not distributable by law, purchase or subscribe to corporate shares or stock;
  • Carry out reductions in share capital, mergers or demergers by violating the rules set to protect creditors;
  • Fictitiously forming or increasing share capital;
  • satisfy, in the event of liquidation, the claims of shareholders to the detriment of corporate creditors.

5.9 Relations with the Public Administration

By relations with the Public Administration is meant all those relations, pertaining to the company's activity, maintained with public officials or public service officers operating on behalf of the Public Administration or national and foreign legislative bodies, EU institutions, public organizations of any foreign state. The same principles applicable to the Public Administration are to be considered valid in cases of relations with Companies or Groups with even partial public capital.
Relations with governmental entities and public institutions are reserved for the corporate functions authorized to establish and manage such relations on the basis of the provisions of the service orders and pro-tempore procedures in force.
Such relationships must be undertaken and managed in absolute and strict compliance with applicable laws and regulations, the standards and principles set forth in the Code of Ethics and the relevant internal procedures.
Particular attention and care must be taken in dealings with the above-mentioned parties, particularly in areas relating to:

  • Tenders,
  • contracts,
  • authorizations,
  • licenses,
  • concessions,
  • Applications for and/or management and use of funding however denominated of public origin (national or EU),
  • management of job orders,
  • Relations with supervisors or other independent authorities,
  • welfare agencies,
  • Tax collection agencies,
  • Civil, criminal or administrative proceedings.

Attention and care must, moreover, be paid to those areas that, although they do not involve direct relations aimed at the conclusion of business with the Public Administration, are considered to support business activities in this sense such as the management of financial flows and the management and security of computer data.
The aforementioned operations and the related management of financial and IT resources must be undertaken in due compliance with the law, the principles of the Code of Ethics and in full compliance with internal procedures.
In particular, it is expressly prohibited to:

  • Accepting, giving or promising, directly, indirectly or through an intermediary, money, gifts, goods, services, benefits or favors to public officials (or to persons related to them by kinship or affinity) in order to promote and favor their own interests or the interests of Sintagma, or even to compensate or repay them for an act of their office, or to achieve the performance of an act contrary to the duties of their office;
  • Receiving, offering or promising gifts or any other form of gift to public officials or persons related to them by kinship or affinity when such gifts, in view of their value and/or type, exceed normal business practices and courtesy or otherwise stand outside the provisions of the company's internal protocols;
  • hiring personnel, awarding agency, consulting or other assignments, where the hiring or assignment is (or may appear to be) aimed at an exchange of favors with persons belonging, or previously belonging, to the Public Administration;
  • Recognize fees in favor of External Collaborators that are not adequately justified for the type of assignment to be performed and in current local practices;
  • Presenting untrue statements or documentation of any kind to public bodies in order to influence their independent judgment and/or decision-making;
  • Submitting untruthful statements or other documentation to national or EU public bodies in order to obtain public disbursements, contributions or subsidized financing;
  • Allocate sums received from national or community public bodies as disbursements, contributions or financing for purposes other than those for which they were intended;
  • Alter the operation of a computer or telematic system or manipulate the data contained therein in order to obtain an unfair profit by causing damage to the Public Administration.

In relations with the Public Administration, it is necessary to always operate in compliance with the law, with the express prohibition of engaging in conduct that, in order to benefit the company, is such as to constitute offenses.

5.10 Technological Codes of Conduct

The use of technology, in particular telematics and information technology, is subject to specific codes of conduct to be issued by Sintagma from time to time. These codes have not been included in the text of this Code of Ethics, given their generally highly technical nature and subject to frequent changes, but they are nevertheless an annex to it and their violation is considered in the same way as violation of the Code of Ethics.
All Recipients of this Code of Ethics are required to comply with these Technological Codes of Conduct, where applicable.

5.11 Relations with Suppliers, Users and Customers

The success of the Company necessarily passes through a correct and transparent relationship with Suppliers and Customers. The satisfaction of Customers' requests and the establishment of constructive relationships with Suppliers represent primary corporate objectives.
Sintagma expects its Directors, Employees and Collaborators, when marketing goods and services and representing the Company in relations with Suppliers and Customers, to comply with the laws and regulations in force in the country where the business relations take place.
All relationships established in the name and on behalf of the Company with other parties, private or public, always within the scope of the pursuit of Sintagma's own objectives, must be established and managed without resorting to illicit or inappropriate means.
In business relations with Suppliers, Users and Clients, company policies must be respected, imprinting relations with the utmost fairness, especially in the management and conclusion of contracts, avoiding conflicts of interest, even potential ones.
Without prejudice to the provisions of Section 5.9 "Relations with the Public Administration," in business relations with Suppliers and Customers, whether they belong to Public or Private Bodies, gifts, acts of courtesy, donations, gratuities or hospitality, (whether direct or indirect) are prohibited unless they are of such a nature as not to compromise the company's image and cannot be interpreted, even remotely, as aimed at obtaining favorable treatment that is not determined by lawful market rules. In any case, any gifts, acts of courtesy and hospitality that do not fall within normal customs because they are of a type or value different from the typical business gadget or customary forms of courtesy, must be adequately documented and communicated to one's supervisor so that he or she may assess their appropriateness.
Any Employee or Collaborator who receives gifts or favorable treatment from Suppliers, Users or Customers that transcend ordinary courtesy relations, must immediately notify his or her hierarchical superior; after the appropriate checks with the Managing Director, the company will, through the functions in charge, inform the author of the gift, gratuity, etc... on the company policy on the matter.
Particular attention must be paid in the management of sponsorships and fiduciary assignments, always ensuring maximum traceability, transparency and lawfulness of the related accounting and financial transactions, as well as verification of the absence of conflicts of interest.

5.11.1 Supplier Relations.

The Directors, Employees and Collaborators of Sintagma are required to ensure equal opportunity in the selection of Suppliers, taking into account their compatibility and suitability to the size and needs of the Company.
In particular, the functions in charge from time to time in selecting independent third parties such as consultants, agents, suppliers of goods, goods and services must ensure that:

  • are selected on the basis of objective evaluations and parameters (quality, convenience, price, capacity and efficiency, ...) aimed at protecting the company's commercial and industrial interests and, in any case, in order to create greater value for the company;
  • are selected according to criteria of reliability and integrity, including the need for compliance with reference values, the rules of conduct contained in the Code of Ethics and internal procedures, using the written form and in compliance with the hierarchical structure of the company;
  • the Company's policies are communicated to them and specific contractual clauses are included regarding compliance with this Code of Ethics.

The functions in charge must also see to it that continuous awareness and involvement of Suppliers in a proactive role and responsible attitude is ensured particularly with regard to transparency, communication, compliance with laws and regulations, safety at work, and that fosters awareness of the social and ethical risks and opportunities arising from their activities.
In particular, SINTAGMA Employees, in dealing with Suppliers, are required to:

  • Strictly adhere to procedures for selecting Suppliers, adopting objective, traceable, explicit and transparent selection criteria;
  • Obtain the cooperation of Suppliers to deliver services and supply quality goods to Customers;
  • Manage relationships with Suppliers according to established procedures, strictly adhering to contractual terms and following good business practices;
  • Immediately report any problems that have arisen with Suppliers to their supervisor.

It is strictly prohibited to accept promises or payments of money, goods, or other forms of utilities, according to the criteria specified in this chapter.

5.11.2 Customer Relations

In dealing with Customers, whether public or private, Recipients are required to:

  • To develop and maintain relations with them marked by maximum efficiency, cooperation and courtesy;
  • Operate within the framework of current regulations and require timely compliance;
  • Ensure that the statements and attestations made to Clients are accurate and true;
  • To fulfill commitments and obligations made to them;
  • Provide accurate, complete, truthful and timely information so that the Client and User can make informed decisions.

It is especially prohibited to accept promises or payments of money, goods, or other forms of benefits, according to the criteria specified in this chapter.

5.11.3 Prevention of Conflicts of Interest

Top Management, Employees and Collaborators acting in the name and on behalf of the Company are required to operate in order to avoid situations in conflict with the interests of Sintagma itself.
By way of example only, but by no means exhaustive, the following constitute conflicts of interest:

  • The instrumentalization of one's functional position for the realization of interests conflicting with those of the Company;
  • The use of information acquired in the performance of work activities for one's own benefit or for the benefit of third parties and otherwise contrary to the interests of the Company;
  • the participation, overt or covert, of the Employee and/or Collaborator in activities of Suppliers, Clients, competing companies;
  • the performance of work activities of any kind with Clients, Suppliers, competitors and/or third parties, in contrast with the interests of the company. In particular, for Employees, the acceptance of any assignment of a professional nature offered by third parties must be evaluated in advance with the hierarchical superior and the Managing Director of Sintagma in order to assess the non-existence of any incompatibilities or situations of prejudice.

Each person has the duty to promptly report to his or her supervisor any situation that may be considered, even potentially, prejudicial to the rights and interests of the company so that it may proceed, just as promptly, with the necessary protective actions.
In particular, anyone who believes that he or she is in an actual or potential situation of conflict of interest, between his or her own interests or those of third parties and those of Sintagma, must immediately notify his or her supervisor.

5.12 Relations with Supervisory Bodies

Relations with Bodies to which legally assigned control or audit activities are entrusted must be marked by the utmost fairness, transparency and cooperation, in full compliance with the laws and regulations in force. This applies both to bodies entrusted by the judicial authority and to bodies of another nature (e.g.: Board of Auditors (if any), Supervisory Board (if any).
In particular, auditors, both internal and external, must have free access to the data, documents and information necessary for the performance of their activities. It is expressly prohibited to prevent or hinder the performance of control or audit activities legally attributed to shareholders, other corporate bodies or auditors and auditing firms.
It is strictly forbidden to make false or incomplete statements to the Control Bodies, whether the Judicial Authority or otherwise. It is strictly forbidden to induce or attempt to induce anyone to make incomplete or false statements to the Judicial Authority or other Control Bodies.

5.13 Environmental protection and preservation

All recipients of this Code of Ethics are required to take the utmost precaution towards the environment, understood as the set of natural resources available to Man as provided for in the Environmental Management System according to ISO14001 present in SINTAGMA.
Their work, in addition to the obvious compliance with current environmental regulations, must be marked by the utmost precaution against risks of damage to the environment.
It is strictly forbidden to undertake, even temporarily, actions that could incidentally lead to environmental damage (e.g., unauthorized waste storage, abandonment of waste, unauthorized waste transport, damage to protected wildlife species) unless this implies imminent danger to human health or the risk of even more serious damage.


Compliance with the principles and rules of the Code of Ethics must be considered an essential part of the contractual obligations of Employees pursuant to and in accordance with Article 2104 of the Civil Code. Violations of the rules of the Code of Ethics may constitute a breach of the primary obligations of the employment relationship or a disciplinary offence, in compliance with the procedures provided for in Article 7 of the Workers' Statute, with all the consequences of the Law, including with regard to the preservation of the employment relationship, and may result in compensation for damages arising from the same.
Observance of the Code of Ethics must be considered an essential part of the contractual obligations undertaken by non-subordinate Collaborators and/or subjects having business relations with Sintagma. Violation of the rules of the Code of Ethics may constitute breach of contractual obligations, with all the consequences of Law, including with regard to the termination of the contract and/or assignment and may result in compensation for damages arising from the same.
For violations of the members of the Board of Directors and the Statutory Auditors, all the rules of law apply, in particular Articles 2392 and 2407 of the Civil Code, with the consequent remedies and sanctions.
Sintagma undertakes to provide for and impose, with consistency, impartiality and uniformity, sanctions proportionate to the respective violations of the Code and in accordance with current provisions on the regulation of labor relations.


7.1 Implementation and dissemination

In order to increase its visibility, the Code of Ethics is published, with appropriate prominence, on the website
This Code and any future updates to it are defined and approved by Management.
SINTAGMA is committed to disseminating the principles of the Code to all interlocutors with whom a business relationship is in place or about to be formalized, with particular regard to human resources, collaborators, partners, and suppliers.

7.2 Monitoring and sanctioning violations

SINTAGMA is committed to enforcing compliance with the rules of this Code through the figure of the Head of Corruption Prevention (RPC) who coincides with the Head of the Integrated Management System.
This figure monitors the application of the Code by the recipients, including through the collection of any reports, including anonymous ones, which can be sent through the following transmission channels:

  • Email
  • online form at
  • Regular mail: SINTAGMA Via Roberta, 2 06132 - San Martino in campo (PG).

All those who report in good faith any violations of this Code are guaranteed complete confidentiality.

7.3 Validity of the Code

This Code is valid for 1 year, which starts from the date of its approval by Management.
At least once a year it is reviewed, supplemented and updated as necessary during the Management Review.
If the PRC figure sees the need for an update of this Code, he/she may do so within a reasonable time and submit it to Management for approval.

7.4 Violations of the Code of Ethics

SINTAGMA, in ascertained cases of violation of the Code of Ethics adopts the most appropriate sanctioning measures to protect the company's interests in compliance with current regulations and collective labor agreements. Applicable sanctioning measures include:

  • Disciplinary sanctions provided for in the applicable collective bargaining agreements;
  • termination of the contract;
  • The application of any pre-established penalty clauses;
  • The claim for damages, including to image.