Ethical Code

 1. Foreword

ANSA curates the collection, publication, and distribution, to its Members and to third parties, of news and of any other communication service, in every form, also based on the development of IT and communication technologies.
In carrying out its activities, the Agency implements the principles of independence, impartiality, and objectivity set forth in its Bylaws and complies with national and international laws. In this context, the implementation of a Code of Ethics is a further step to formalise and outline the set of values that inspire the Agency in achieving its purposes and to provide value to its Members.

 2. Scope of application and addressees

The principles and provisions of this Code of Ethics are binding for Directors, top management, employees, and collaborators, as well as for all those who are bound by a contractual relationship – even occasional and/or temporary – with the Agency (hereinafter “addressees”). In particular:

  • the members of the Board of Directors and of the Executive Committee must comply with the principles of this Code of Ethics in establishing the company’s goals, proposing investments, and carrying out projects, and in any decision or action taken while managing the Company;
  • managers must comply with the same principles in managing the Company both within the company, enhancing cohesion and spirit of mutual cooperation, and with third parties that come into contact with the company;
  • employees, freelance collaborators, business partners, and anyone who has business relationships with the Company are also expected to comply with the provisions of this Code of Ethics, according to the different relationships with the Company.

 3. Principles of reference

The company applies the following principles to achieve its goals:

  1. compliance with all the provisions of law and regulations in force in the countries where the Company operates;
  2. compliance with the strictest behavioural rules concerning relations with the Public Administration, respecting institutional functions;
  3. equality and impartiality;
  4. honesty, transparency, and reliability;
  5. loyalty, fairness, and good faith;
  6. confidentiality;
  7. respect for employees and freelance collaborators and of all people in general;
  8. environment protection and occupational safety.

 4. Prevention of conflicts of interest

The goals and purposes of the activity of each addressee must pursue only the general interests of the Company; therefore it is essential to prevent situations of conflict of interest. These are intended as situations where an interest other than the company’s mission is pursued or activities that interfere with the ability to make decisions in the sole interest of the company or situations where one takes personal advantage of the company’s business opportunities or where representatives of clients, suppliers, public institutions, public officers or public service officers act in contrast with the duties imposed by their position. Conflicts of interest include but are not limited to:

  • latent or patent interest of an employee in the activity of suppliers, clients, and competitors; instrumentalisation of one’s position to pursue interests in contrast with those of the company;
  • the use of information acquired whilst carrying out work activities to their own or to third parties’ advantage in contrast with the interests of the company;
  • any work activity (provision of services; intellectual works) for clients, suppliers, competitors and/or third parties, in contrast with the company’s interests.

 5. Confidentiality of information

The Company ensures the confidentiality of all the information it has and refrains from searching and using confidential data, except for the case of expressed and aware authorisation, and always in compliance with the privacy laws and company procedures in force.
According to their different relationships with the Company, Addressees must not use confidential information for purposes that are not related to the activity they have been entrusted with.

 6. Corporate governance

The Company ensures the participation of Members in the decisions that fall within their competency, thereby ensuring equality, transparency, clarity, and completeness of information concerning the situation and trend of the company, as well as the right to access said information.

 7. Accounting records

Every operation or transaction must be correctly recorded in the company accounting system, according to the criteria indicated by law and by accounting principles and must be duly authorised, verifiable, lawful, and consistent. Every operation must be backed by relevant documentation in order to allow for checks at any time to certify characteristics and motivations of the transaction and verify the decision-making, authorisation, and implementation processes, as well as to identify the various levels of responsibility.

 8. Human Resources

The Company acknowledges the importance of Human Resources for its development and success.
The management of labour relations and collaboration must be based on the respect for workers' rights and professionalism. The value and growth of human resources must be based on individual competencies and skills, with no discrimination whatsoever, thereby providing and implementing training and/or qualification activities.

 9. Safety and Environment

The Company ensures a safe and healthy workplace by taking all the measures provided by law. The Company undertakes to develop and disseminate a culture of safety, thereby raising awareness of the risks and promoting responsible behaviour among employees and collaborators.
The Company takes special care in carrying out operations whilst respecting the environment and public health, in compliance with the standards in force.

 10. Relations with third parties

Clients The conduct with clients is based on helpfulness, fairness, and professionalism, in order to ensure prompt and qualified responses to clients’ requirements and build a polite and collaborative relationship.
Products and services provided must fully meet the clients’ expectations without discrimination or partiality. The Company undertakes to effectively and promptly examine suggestions and complaints from clients.

Suppliers Procurement processes are based on the search for the greatest competitive advantage for the Company and on granting equal opportunities to every supplier, thereby ensuring loyalty and impartiality.
The selection of suppliers and determination of the terms and conditions of purchase are based on an objective evaluation of the quality and price of the goods or service, as well as on the guarantees regarding support and timeliness. All this is subjected to periodic revisions to maintain a high standard.

Public Administration and Public Institutions The Company’s relations with the Public Administration are based on compliance of the provisions of law and of the applicable regulations and cannot compromise the Company’s integrity and reputation in any way.
Commitments and management of relations of whatever type with the Public Administration are reserved to the appointed company functions and to authorised personnel.
In relations with public bodies, representatives, employees, and collaborators are not allowed to pay or offer, directly or through third parties, amounts to compensate or repay public officers or subjects appointed to public service and/or other employees of the Public Administration or other Public Institutions or their families, for activities that fall within the tasks of their office or to obtain an act in conflict with the duties of their office.
Business courtesy acts, such as gifts, in-kind donations, forms of hospitality, or any other forms of benefit (even in the form of donations) are allowed only if these do not compromise the integrity and reputation of the parties and cannot be interpreted as acts intended to gain advantage and personal favours. In any case, these must always be authorised and duly documented.

Unions and political organisations The Company undertakes not to allocate funds, directly or indirectly, to political parties, movements, committees, and political organisations and trade unions or to their representatives or candidates, except for cases of funds due on the basis of specific regulations

 11. Supervisory Board

The following tasks are appointed to the Supervisory Board, as outlined by the guidelines of the organisation, management and control model, pursuant to Italian Legislative Decree 231/2001, implemented by the Company with a resolution of the Board of Directors:

  • Verifying the application of and compliance with the Code of Ethics and organisation, management and control model;
  • Receiving and examining reports of breaches of the Code;
  • Taking all the measures deemed necessary in the event of breaches of the Code;
  • Expressing opinions concerning the revision of company procedures and directives to ensure consistency with the provisions of the Code;
  • Suggesting revisions and/or integrations of the Code and models to the Board of Directors and the CEO.

 12. Communication and training

The Company undertakes to disclose the Code of Ethics to the addressees by means of an appropriate information and awareness-raising plan to promote the knowledge of the principles and rules contained in it.

 13. Breaches of the Code of Ethics

Compliance with the provisions of this Code of Ethics andorganisation, management and control models is considered as an essential part of the contractual obligations that bind the employees, pursuant to art. 2104 of the Italian Civil Code. Breaches of the Code of Ethics may constitute defaulting the primary obligations of the employment relationship or disciplinary offence, in compliance with the procedures provided for in art. 7 of the Workers’' Statute, with all the consequences provided by Law, even concerning termination of the contract and/or appointment and may involve compensation for damage.
Compliance with the Code must be considered as an essential part of the contractual obligations that bind freelance collaborators and/or people have business relations with the Company. Breaches of the Code of Ethics may constitute a breach of the contract, with all the consequences provided by Law, even concerning termination of the contract and/or appointment and may involve compensation for damage.

 14. Final provisions

This Code of Ethics is approved by the Company’s Board of Directors. Any amendment and/or integration must be approved by the Board of Directors and promptly notified to the recipients.