ARTICLE 1 – PREAMBLE

The current Code of Ethics of qnpSoft lnc. (hereby on “Company”) is a fundamental part of the Company’s organizational model and of its comprehensive control system, because the Company believes that only working with ethics can guarantee the economic success of a business.

ARTICLE 2 – GOALS AND VALUES

The key values that inspire the daily activity of all the staff are:
client satisfaction, which is the main goal of the Company. It strives for the establishment of a high-quality relationship with its clients and for loyalty building by providing them with services and products that comply with the needs, status, culture and expectations of each single client;
service personalization, i.e. the effort of each member of the staff towards the best possible solutions for the clients and towards effective working procedures in the Company;
compliance with internal and external rules and laws, i.e. abiding primary and secondary laws and to all related legislation. This means also rejecting each kind of illicit behaviour, even if coming from the clients;
ethical behaviour, i.e. respecting the quality standards of conduct described in this Code of Ethics;
fair return on risk capital to individual participants, i.e. the constant search for an adequate return given the complexity and the overall risk involved in the activities the Company carries out;
investing towards the improvement of services provided and towards the continuous improvement, both cultural and professional, of each member and employee.

These key values are general principles and should be considered by the clients as the Company’s hallmarks, distinguishing it from its competitors.
The primary objective of the Company is to protect each single client, allowing them to operate with maximum peace of mind in a legal setting that is constantly changing and whose interpretation is problematic, resulting in savings of time and human resources.
Another primary goal is to add value to the members, while respecting the principles established by this Code of Ethics. The commercial and financial strategies of the Company are devoted to this end, together with the resulting operations inspired by the efficient use of resources.

The Company:
is bound to respect and enforce in its practice the Italian laws as well as the ethical principles of mutual acceptance, according to international standards in the conduct of business: transparency, fairness and loyalty;
rejects and condemns the use of illegal and otherwise improper conduct (towards the community, public authorities, clients, employees, suppliers and competitors) to achieve its economic goals, which shall be pursued exclusively through excellence of performance in terms of quality and convenience of services, based on experience, on customer care and on innovation;
adopts organizational measures to prevent violations of law provisions and of the principles of transparency, fairness and loyalty from their employees and partners, and ensures the observance and implementation of the above-mentioned provisions;
pursues excellence and competitiveness in the market, offering its clients quality services that respond effectively to their needs;
protects and develops human resources it uses;
uses resources responsibly, aiming at a sustainable development which respects the environment and the rights of future generations.

ARTICLE 3 – INTERNAL CONTROL SYSTEM

The efficiency and effectiveness of the internal control system are the basis of the professional activity in accordance with the rules and principles of this Code of Ethics. All recipients of the Code are therefore required to help ensure it works and to guarantee its best functioning.

In the internal control system are of particular importance the proper definition of tasks and responsibilities, with a coherent labour division and reliability of accounting and management data.
The collection, storage, processing, presentation and dissemination of accounting and management data in the manner and terms required by the corresponding law and in line with company procedures represent a priority for the Company. The pursuit of this objective – which requires the cooperation of all recipients of the Code – is primary responsibility of the Company’s persons in charge of accounting and management control.

ARTICLE 4 – RELATIONS WITH THIRD PARTIES

4.1 Members

The Company is committed to ensuring equal treatment to all the members, without any preferential treatment.

4.2 Clients

The excellence of the services provided by the Company is based on customer service and on the willingness to meet its clients’ needs. The aim is to ensure an immediate, professional and competent response tailored to meet the clients’ needs, always behaving in a fair, polite and cooperative way.

4.3 Human resources

The Company recognizes the centrality of human resources in the belief that the main factor for the success of any business is the professional contribution of the people who work there, in a climate of fairness and mutual trust.

The Company safeguards the health and safety in the workplace and consider essential, in the performance of economic activity, the respect of workers’ rights. The management of professional relations is aimed at ensuring equal opportunities and at promoting the development of each individual.

ARTICLE 5 – CODE RECIPIENTS’ CONDUCT

The recipients of the Code operate and work with diligent and scrupulous care, in compliance with the rules and position attributed to them; their conduct must aim at the objectives and strategies of the Company. Furthermore the organization, therefore every member of it, is obliged to monitor the satisfaction of clients and their perception about whether the organization has met their requirements or not. This represents a measure of the quality management system’s performance.

The conduct of the recipients of this Code, the members of the social bodies, the Company’s managerial staff and employees in their professional activity and relations arising there from shall comply with the provisions of the legal system, with this Code of Ethics and with corporate procedures.

It is forbidden:
to pursue personal or third parties’ interests at the expenses of company interests;
to exploit abusively the name and reputation of the Company for personal or third parties’ interests, as well as the information gained and the business opportunities foreseen during the performance of their duties;
to use corporate assets for purposes other than those provided for.

The recipients of the Code shall refrain from activities (including pro bono activities), behaviours and actions inconsistent with the obligations that come from the professional relation they have with the Company.

It is compulsory for the Company’s employees and staff to report to their direct superior and / or supervisor the arousal of any potential conflict between direct or indirect self-interest and the interests of the Company; reporting is also required in cases of doubt.

The recipients of the Code ensure the confidentiality of information acquired or processed during their professional activity.

ARTICLE 6 – PROFESSIONAL TRAINING

The quality of human resources is an asset of paramount importance to the existence and development of the Company. The professional partners take care of the constant updating of their level of knowledge, and they also take care of the cultural and ethical development of their staff and employees.

ARTICLE 7 – CONFIDENTIALITY

The members of the organization are bound to absolute confidentiality on all information and documents which are acquired during their professional activity, with reference to the Company’s clients. In addition to the areas prescribed by law, must be considered confidential also the internal organization of the Company, its internal legislation, and its current and/or past projects, ideas, debates and situations.

ARTICLE 8 – RESPECT OF THE CODE OF ETHICS

The Company is committed to adopting the procedures, rules or instructions aimed at ensuring that the values stated by this Code are reflected in the behaviour of all employees and staff members, providing – where appropriate and in compliance with the applicable provisions – specific sanctions for possible violations.

All members, partners, employees and staff members should report promptly in writing to their supervisors any possible violation or induction to violate the law, the regulations, the requirements of this Code and the internal procedures. They should also report any irregularities or negligence in the keeping of accounting records or files, in the storage of relevant documents and in the compliance of internal accounting and management reporting duties.

The supervisors shall carry out the necessary checks on the reports received in order to establish the facts and to promote the most appropriate course of action, including, when applicable, proposing punitive measures against those responsible for improper behaviours. The above-mentioned punitive measures should comply with the law, collective agreements and/or contracts.

There will be no negative consequences for those who, in good faith, shall report an irregularity or negligence. It is in any case ensured that the identity of the reporting person will be kept confidential, subject to the requirements of the law.

ARTICLE 9 – MONITORING AND UPDATING OF THE CODE

This Code shall be subject to periodical verification and, if needed, updates.