ETHIC CODE


The values inside this ETHIC CODE have always inspired the behavior of all of us. You will find it organized in a structured way, clearly highlighted in a document easy to refer to, and that in the same time points out also the principles of behavior that follows. In our intentions, in fact, this Code should help to reach two important targets: on one hand, to stimulate and strengthen their sense of belonging, tuning the behavior of all on the other hand, to contribute by confirming the image of a reliable Company, ensuring a correct setting of relationships with those people, for any reason, in contact with DHA EVOLUTION. This is the spirit that has united us in writing down this document and we are sure it’s in the same spirit it will be understood by you all.

1. PREMISES

DHA Evolution, in conduct of its’ shares , refers to ethical principles which are derived from individual and corporate values consolidated through time. These values are mainly: - Moral integrity, personal honesty and correct relationships inside and outside; - Respect for employees and commitment to enhance professional skills; as well as rejection of any conduct that might be finalized to reach a consistent result in the interest of DHA Evolution, but having incompatible aspects with the organization model of absolute respect of the rules of behavior applied in DHA Evolution. The necessity to share in the broadest possible way the values of this formal document, The Ethic Code, permits the diffusion of these values in DHA Evolution so all those who are part of it can behave consistently during their everyday work. DHA Evolution consequently engages itself to monitor the compliance of such Ethic Code, by providing suitable instruments of information, prevention and control and to intervene, when necessary, with appropriate corrective actions.

2. RECIPIENTS

The Ethic Code is applied to all those who operate in DHA Evolution, employees and subjects providing their contribution in the corporate activity of DHA Evolution. All employees have the right and duty to know it, to apply it, to ask for explanations in case of doubts and/or to report any eventual identified deficiencies . It is to be diffused to all third subjects with which DHA Evolution co-operates with during their corporate working activity. Employees must:
-Inform third parties about the Ethic Code including duties for DHA Evolution employees. Make sure that the third party complies with the requirements of the Code of Ethics of DHA Evolution. -Report to their superiors infringement by third parties of the duties, in order to respect the Ethic Code to which they refer to. Every person has the right/duty to consult their superiors in case of need for clarifications on how to apply the rules of the Code of Ethic.

3. RESPECT AND ENHANCEMENT OF HUMAN RESOURCES

Human resources are indispensable elements for the existence, development and success of the Company. DHA Evolution pays particular attention to the enhancement and development of skills and abilities of all employees in order to express the best of their potential and their professionalism. DHA Evolution offers to all their employees equal working opportunities in accordance to professional characteristics, and without discrimination. For this purpose, DHA Evolution is committed to: -recruit, hire, compensate, train and evaluate employees on the basis of merit, competence and professionalism, without any discrimination policy, trade union, religious, racial, language or sex; -do not use child labor -ensure a working environment in which the relationships between colleagues are based on honesty, fairness, cooperation, mutual respect and trust; -provide adequate working conditions from the point of view of safety and health, as well as respect of the moral personality of all, in such a way as to foster interpersonal relationships free from bias; -intervene in case of attitudes that do not comply with the above principles; -combat, in particular, any form of intimidation, hostility, isolation, undue interference or conditioning, sexual harassment. Training is the means by which DHA Evolution has always taken steps to enhance the professionalism in the company, through programs of growth and development.

4. BUSINESS MANAGEMENT

Employee behaviours

The behavior of employees in achieving their goals and the conclusion of each operation must be based on the principles of honesty, transparency, integrity and fairness, in compliance with company policies. This commitment must also apply to consultants, and in the name and on behalf of DHA Evolution. Employees may not begin or continue any relationship with those who do not intend to comply with these principles: also do not have to also out of corporate business, engaging in conduct and operations that may be in conflict with interest and/or in competition with DHA Evolution, or that could interfere with their ability to make decisions impartially in performance of their duties. For example to be avoided: -The acquisition of financial holdings (direct and indirect) or other economic interests in competition with DHA Evolution by customers or suppliers, with the exception of shares and financial instruments listed on regulated markets -The performance of work activities, or otherwise remunerated, at business customers, suppliers or in competition with DHA Evolution. -Misuse of confidential information, acquired in function of the position, in such a way as to obtain an economical advantage for themselves or for their family members
-Acceptance for themselves and for their family members of cash gifting, or in kind, or other favors from persons who are or who want to enter into business relationships with DHA Evolution, if these gifts in kind are of little value or usefulness and are not attributable to normal and correct relationships. Outside of such case each individual must inform their superiors and refuse. Giving money, gifts, promises of jobs, or other favors to managers, officers or employees of the Public Administration or to their relatives are not allowed. Such can be interpreted as aimed at securing advantages of any kind in an improper way, except in the case of things or items of modest value, which in any way compromise the integrity or reputation of both parties. In any case, these expenses must be authorized by those in possession of the necessary power and adequately documented.

Relationships with customers

In relationships with clients, employees must: -Strictly follow the internal procedures -Operate with courtesy and efficiency, in accordance with the provisions in the contracts and offering only products or services of the mishore quality standards expected from DHA Evolution. -Provide customers with accurate, complete clear and truthful information regarding products or services offered, as to allow the other party a conscious choice -Not to disclose communications that in any way may be misleading The behavior of DHA Evolution towards its customers is in the respect of the principles of availability, professionalism and courtesy. The objective of DHA Evolution is the complete satisfaction of its customers.

Relationships with suppliers

In relations with suppliers, employees must: -Follow the internal procedures for the selection and award of supply and acceptance of products or documenting performance in a clear and transparent evaluation criteria, in order to ensure the maximum competitive advantage for DHA Evolution, and assurance of compliance with the best quality of products offered to DHA Evolution. -To enforce and comply with the contractual conditions -Avoid the use of suppliers with whom they have a family relationship or affinity -Take all possible precautions necessary to prevent the use of suppliers that are not in turn inspired by the ethical principles of DHA Evolution.

Use and protection of corporate assets

All employees and consultants should remember that corporate and intangible assets made available to them by DHA Evolution are used: -With utmost care and in their own way, in order to avoid damage to things or persons -Avoiding as far as possible, waste, tampering or uses that might compromise the efficiency or accelerate the normal deterioration -Exclusively for purposes related to work activity -Completely avoiding the use or sale of the same goods from a third party, even temporarily All employees and associates are responsible for the use and custody granted to them by the Company. Also the equipment and applications should be used in compliance with the above and in particular: -Carefully following the safety policies and business confidentiality -Avoiding use or transmission, especially of massive information and contents which are not work-related. -Not altering the hardware and software configurations provided by the Company -In compliance with applicable laws, Company carries out checks and implements measures to prevent behaviours that are not in line with what was mentioned. All employees must also operate in order to reduce the risk of theft, damage and external threats of the resources allocated in the Company, promptly notifying the relevant units in the case of abnormal situations.

5. USE AND DISCLOSURE OF INFORMATION

DHA Evolution considers the dissemination of accurate and complete corporate information and maintaining the confidentiality due on them when necessary. As a result, in information management, employees must: Carefully retain in the strictest confidence all corporate information of any kind (personal data of employees, organizational data, data pertaining to negotiations, financial operations, know-how, patents, plans, strategies and market analysis etc..) -Require the consent of processing personal data for purposes notified first. In relation to information in general, employees must: -Prevent misuse of ones own confidential information regarding or those of family members, acquaintances and others in general -Protect against unauthorized subjects in order to avoid spreading -Not to seek or try to get from others information which is not related to ones own sphere of competence or functions. Classify and organize the information so that it is possible for authorized individuals to access easily, obtaining a complete picture of the situation.

6.TRANSPARENCY IN ACCOUNTING

In keeping documentation and accounting records, the principles of truth, clarity, completeness, correctness of all information, must be absolutely respected.
Consequently the employees must: -Represent operational management with transparency, truth, accuracy, and timely manner, in order to facilitate the accounting process as a whole and in accordance with agreed procedures. -Properly record, without any omissions economic financial transactions -Maintain adequate documentation for operations and transactions, so as to facilitate the reconstruction of the decision-making process verification and authorization, the latter based on the appropriate levels of responsibility -Store these documents in a logically organized way as to allow easy availability -Enable the carrying out of checks that confirm the nature and reasons of the operation -Provide internal control bodies the necessary information in a complete and trustworthy way

7. HEALTH SAFETY AND ENVIRONMENT

DHA Evolution is convinced that the full compatibility of its activity with the territory and surroundings is a primary condition. DHA Evolution constantly strives so that its working activity is conducted with full respect for the health and safety of employees and third parties, as well as the environment. Always consistent with the principles above, DHA Evolution has imposed a ban on smoking in all indoor workplaces.

8. EXTERNAL RELATIONS

Even in relationships with persons in respect of whom do not have a contractual relationship of any kind, DHA Evolution is aware of total respect of all principles and values contained in the Code of Ethic. In particular, relations with public institutions and protecting the interests of DHA Evolution at the same should be managed by business functions that have been delegated or with assigned responsabilities. As for the freebies or other acts of kindness and for the conduct of the negotiations see as specified in point 4. If in relations with public institutions DHA Evolution wishes to make use of third-party consultants or representatives, the latter must conform their conduct to the requirements in the Code of Ethics. DHA Evolution does not make contributions, direct or indirectly, in any form, to political parties, movements, trade union committees or other political organizations, nor their representatives or candidates, except in cases due according to specific regulations. Employees must not make or promise similar donations on behalf or in the interest of the Company.

9. CONCLUSIONS

Right from the introduction to the Code of Ethics, it is clear that the respect of all laws on behalf of each single employee of the Code of Ethics while carrying out its work has a very strong appeal. Respecting the Code of Ethics on the other hand, must be born by more than just an obligation imposed by DHA Evolution towards its employees, sharing the fundamental values declared inside. This does not exclude, however, the right and duty of DHA Evolution for ensuring compliance with the Code of Ethics, putting in place all actions, prevention and inspections considered necessary or opportune.