Unidata.it

GOVERNANCE

CORPORATE ETHIC

Business ethics represents an essential component of the internal control and risk management system that could compromise the responsible conduct of business.
The control system is the set of rules, procedures, and organizational structures aimed at ensuring correct and consistent corporate management in line with the objectives set by the Company, through the identification, measurement, management, and monitoring of main business risks.
The rules and procedures contribute to ensuring the safeguarding of corporate assets, the efficiency and effectiveness of business processes, the reliability of financial information, compliance with regulations, and, above all, transparency in the activities carried out.
The management structure of Unidata S.p.A. is organized to ensure transparent procedures capable of guaranteeing and fostering the control and prevention of conduct that does not align with the founding principles of honesty and integrity, merit and fairness, commitment and professional ethics.
The control system creates a synergy between the principles and rules contained in the Code of Ethics and the 231 Organizational Model, contributing to informed decision-making that aligns with risk appetite and remains transparent toward institutions, customers, and the entire community.
To maximize transparency, Unidata S.p.A. has also implemented a reporting procedure, known as whistleblowing: a legal tool through which employees and external parties, while fully respecting identity confidentiality, can promptly report fraud, a risk, or a situation of potential harm.

During its meeting on March 21, 2023, the AGCM (Italian Competition Authority), having examined the application for the Legality Rating submitted by Unidata S.p.A., resolved—based on the declarations made and the assessments performed—to award the score: ★★+

AGCM – Legality Rating attribution letter to Unidata S.p.A.

“The legality rating is a tool introduced in 2012 for Italian companies, aimed at promoting and introducing principles of ethical behavior within the corporate environment by awarding a ‘recognition’—measured in ‘stars’—which indicates compliance with the law by the companies that have applied for it and, more generally, the degree of attention paid to the correct management of their business” (source: mimit.gov.it)

CORPORATE VALUES

Unidata has always been sensitive to the principles of corporate social responsibility, firmly believing that management efficiency and cost-effectiveness must be inextricably accompanied not only by ethical sensitivity, but also by social engagement and respect for the environment. This sensitivity is reflected in the ability to combine and integrate different objectives into the achievement of the corporate mission, such as attention to the needs of the community and respect for the environment, and the promotion of a workplace inspired by respect, fairness, collaboration, and the enhancement of professional skills.

To confirm the importance attributed to ethical profiles and, in particular, to emphasize the relevance of conduct based on rigor and integrity, Unidata has adopted the Code of Ethics, which represents a foundational component of the company’s Internal Control System and a tool for corporate culture. The Code of Ethics defines the set of core values, reference standards, and rules of conduct for the company, and establishes binding principles, without exception, for all corporate representatives, employees, and any other individual acting, directly or indirectly, in the name and on behalf of the Company.
It plays a fundamental role in Unidata’s credibility within both the civil and economic context, translating the appreciation of the values that characterize the company’s way of operating into a competitive advantage. Everyone who works for UNIDATA has a specific commitment to observe and ensure compliance with the principles of the Code.

The Code of Ethics forms the basis of the 231 Model, which is the organization and management model adopted by Unidata pursuant to Legislative Decree 231/2001, aimed at preventing the commission of offenses that could entail administrative liability for the Company. Unidata is committed to the widest possible dissemination of the principles contained in the Code and to the continuous monitoring of their compatibility with the evolution of the reference regulatory framework. Any information regarding the Code and its application and/or any violation or suspected violation of the Code can be reported to the Supervisory Body at the following email address: odv231@unidata.it.

Codice etico .pdf

Organization, Management, and Control Model pursuant to Legislative Decree 231/2001

Legislative Decree no. 231 of 2001 introduced into the Italian legal system the administrative liability of Companies for specific offenses materially committed by directors, representatives, or employees, in the interest or for the benefit of the Company itself, resulting in financial and disqualification penalties against the Company.
The Company’s liability is excluded if, prior to the commission of the offenses, it has adopted and effectively implemented organization, management, and control models suitable for preventing such offenses, and has established a Body responsible for supervising the functioning and compliance of these models.

In compliance with the provisions of the aforementioned Decree, Unidata has adopted its own Organization, Management, and Control Model (or “Model”), a Code of Ethics serving as a charter of ethical and social values for all those involved in the company, and has entrusted a Supervisory Body, equipped with autonomous powers of initiative and control, with the task of supervising the functioning and compliance of the Model and ensuring its updating. The Model consists of an organic set of principles, rules, and provisions regarding the management and control of each business process.

The Model adopted by Unidata is consistent in its content with the provisions of the Decree and is part of the Company’s broader policy aimed at raising awareness among both internal personnel and external collaborators and business partners regarding transparent management that respects existing regulations and the fundamental principles of ethics in pursuing its corporate purpose. The Model consists of a “General Part” and individual “Special Parts” prepared for the various types of Offenses and Illicit Acts to be prevented.

The Supervisory Body is responsible for monitoring compliance with the provisions of the Organizational Model, verifying their actual effectiveness, and assessing the need for any updates, including in relation to “risk areas.”

Any information regarding the Model and its application and/or any violation or suspected violation of the Model can be reported to the Supervisory Body at the following email address: odv231@unidata.it

model 231

Reporting of misconduct and irregularities (oppure Whistleblowing)

By “whistleblowing” (hereinafter also referred to as “Report”) is meant any information concerning suspected conduct that does not comply with the provisions of the Code of Ethics of Unidata Spa and the 231 Organizational Model adopted by the company, internal procedures, and external regulations applicable to Unidata Spa, as well as complaints and reports received by the Board of Statutory Auditors for matters within its competence.

In accordance with the provisions of Law 179/2017 “Provisions for the protection of authors of reports of crimes or irregularities that came to their knowledge within the context of a public or private employment relationship” and Legislative Decree no. 24 of March 10, 2023, Unidata S.p.A. has adopted a “whistleblowing policy” procedure for managing reports and implementing the actions designed to protect those who report illegal acts and irregularities.

The Whistleblowing system is the tool through which protection is guaranteed to those who report non-compliance in good faith. The objective of this tool is to prevent the occurrence of irregularities within the organization, as well as to involve all Stakeholders in activities to counter non-compliance through active and responsible participation.

Download and review the new Whistleblowing Procedure, approved by Unidata’s Board of Directors on December 14, 2023.

WHY REPORT

Because it is both a right and a duty to protect our work, our company, our colleagues, our clients, and our collaborators. The objective of adopting this tool is to prevent non-compliance or irregularities within the organization, as well as to involve all stakeholders and the public in general in countering illegality through active and responsible participation.

WHO CAN REPORT

The recipients of the Whistleblowing Policy (hereinafter “Recipients” and/or “Whistleblowers”) are:

  • members of corporate bodies, and Unidata employees;
  • clients, suppliers, partners, consultants, and, more generally, Unidata stakeholders.

HOW TO REPORT

Alleged violations, committed by internal personnel, collaborators, and business partners, attributable to the following aspects:

  • violations of laws and regulations
  • fraud
  • human rights
  • violations of the Code of Ethics
  • violations of the Organization, Management, and Control Model pursuant to Legislative Decree 231/2001 231/2001
  • other violations.

Since there is no exhaustive list of crimes or irregularities that can be the subject of a report, reports referring to conduct, crimes, or irregularities that cause harm or detriment to Unidata S.p.A. are also to be considered relevant.

WARNING!

If you are a Unidata S.p.A. customer and wish to report issues of a different nature (commercial, technical, etc.), DO NOT use this form; instead, please consult one of the channels listed in the contact section.

Go to the contact section

PROTECTION OF THE WHISTLEBLOWER

Unidata S.p.A. is committed to protecting those who have made a report in good faith from any form of intimidation or retaliation. Reports are handled confidentially, and the identity of the whistleblower, when disclosed by themselves, will not be revealed without their consent. A well-made, substantiated, and detailed report can be managed without further involvement of the whistleblower. In any case, all information will be treated in accordance with strict confidentiality criteria.

PROTECTION OF THE REPORTED PERSON

During the internal investigation process of the report, all rights of the reported person will be fully guaranteed, and under no circumstances will any proceeding be initiated in the absence of concrete evidence regarding the content of the report itself.

HOW TO REPORT AND TO WHOM

The task of managing reports related to matters falling under Model 231 is entrusted to the Supervisory Body (Organismo di Vigilanza) of Unidata S.p.A. To facilitate reporting, specific communication channels have been established:

REPORTS" PLATFORM

The platform is managed by an independent third party, separate from Unidata. The digital platform utilizes an encryption protocol that ensures the protection of the whistleblower's identity and personal data; however, the whistleblower can still communicate with Unidata's designated body in an anonymous and impersonal manner using a unique code obtained after submitting a report.

REGULAR MAIL

by postal service in a sealed envelope addressed to the Whistleblowing Officer: Head of Internal Audit of Unidata S.p.A., Dr. Sergio Beretta, Viale A.G. Eiffel, 100 – Commercity M26, 00148 Rome