Art. 1

Purpose and scope of application

1. This Code of Ethics (hereinafter, the “Code”) contains the guiding principles of the
behavior of all subjects (hereinafter, the “Subjects” and, individually, the “Subject”)
who, for whatever reason, operate at Studio Gullì (hereinafter the “Studio”) and
specifies the duties of loyalty, impartiality, diligence and industriousness that the
Subjects must apply.
2. The activity of the Subjects must comply with the position of independence
inherent in the activity of chartered accountant, with the guarantee duties
entrusted to chartered accountants, with the impartiality of the activity of chartered
accountants as well as with respect for confidentiality obligations.
3. The Code applies to all those who work at the Firm in any form, full-time or parttime,
in the form of subordinate or non-subordinate work, to trainees, consultants
and persons authorized to attend the Firm to carry out studies or searches.
4. The rules of law and deontology applicable to chartered accountants, with which
the Persons in any case comply, as far as they are entitled and competent.

Art. 2

General provisions

1. Each Person undertakes to comply with the Code and to behave in a manner
inspired by the principles of loyalty, impartiality, integrity and honesty.
2. Each Subject avoids any act or behavior that violates or could lead to believe that
the provisions of the law or regulation or those contained in the Code are violated.
3. Relations between the Firm and each Subject are based on trust and
collaboration. Each Subject takes steps to ensure that relations with each other
Subject are inspired by harmony and avoids acts or behaviors characterized by
animosity or conflict.
4. Each Subject conforms their activity and the use of the Firm’s assets to the criteria
of correctness, economy, efficiency and effectiveness.
5. Each Subject dedicates the right amount of time and effort to office work,
avoiding undue absences or removals.
6. Each Subject limits any use of telephone equipment, photocopiers and computers
for personal reasons to cases of absolute necessity, even in the event of receiving
communications.
7. In external relations, each Subject behaves in such a way as to establish trust and
collaboration on the part of all those who come into contact with the Firm; shows
courtesy and willingness in communicating with the public and deals with matters in
an efficient and prompt manner.

Art. 3

Impartiality

1. Each Subject operates with impartiality, avoids favorable treatment and unequal
treatment, refrains from applying undue pressure and rejects it, adopts initiatives
and decisions with the utmost transparency and avoids creating or benefiting from
privileged situations.
2. In relations with all those who are interested in the activity of the Firm in any
capacity, each Subject does not undertake commitments or formulate personal
promises which may condition the fulfillment of the official duties.
3. Each Subject, without prejudice to the right of association and the right to join
political parties and trade unions, communicates to the owners of the Firm the
membership of associations, circles or other bodies of any nature whose interests
may influence the performance of the functions of office.

Art. 4

Integrity

1. Each Subject does not use the Firm to pursue ends or to achieve private and
personal benefits.
2. Each Subject does not make use of the position he holds in the Firm to obtain
utilities or benefits in external relationships, even of a private nature. In private
relations, each Subject avoids declaring or implying his position in cases where such
mention does not respond to objective needs.
3. Each Subject does not use information not available to the public or not made
public, obtained even confidentially in the course of office activities, to make profits
or private interests.
4. Each Subject avoids receiving benefits of any kind, which may be or appear such
as to influence their independence of judgment and impartiality; moreover, it does
not solicit or accept, for itself or for others, any gift or other benefit from all those
who are in any case interested in the activity of the Firm or who intend to enter into
a relationship with it, with the exception of gifts of modest value.
5. In the event that he receives unlawful pressure or is offered gifts, benefits or
other benefits exceeding a modest value, each Subject is required to promptly notify
the owners of the Firm.

Art. 5

Particular rules

1. Outside of the ordinary procedure for assigning files, each Subject does not solicit
or receive communications intended for him, nor does he send unauthorized
missives.
2. Each Subject participates only in meetings and meetings, even informal, relevant
to the office activity in which he is authorized to take part; it also avoids
unauthorized contacts with recipients, even indirect ones, of the Firm’s activity or
with anyone who supplies or intends to supply goods or services to the Office.
3. Participation of Subjects in conferences, seminars and debates is authorized on
the basis of the criteria of transparency, competence, opportunity and rotation,
subject to a declaration regarding the amount of any reimbursement, token or
compensation received for any reason, or regarding the use of particular benefits.

Art. 6

Conflict of interest

1. Each Subject takes steps to prevent situations of conflict of interest with the Firm
and informs the owners of the Firm of any interests, including of an economic
nature, that he, his spouse, relatives within the fourth degree or cohabiting subjects
have in the activities or in the decisions within its competence.
2. In any case, each Subject abstains from participating in activities or decisions that
determine such a conflict, and provides the owners of the Firm with any further
information requested.
3. Each Subject refrains from participating, for a period of at least two years, in the
discussion of matters that may involve the interests of their previous business
associates or, except in the cases in which they are authorised, of their previous
employers.
4. Each Subject abstains in any other case in which there are serious reasons of
convenience or in which, also due to serious enmity, his or her participation in the
discussion of the matter could generate distrust in the impartiality of the Firm.
5. Each Subject shall promptly inform the Firm’s owners of any contacts initiated, for
the purpose of taking on assignments or activities outside the Firm, with all those
who are interested, even if only potentially, in the Firm’s activity.
6. This Code commits each Person who ceases to work for the Firm not to be in a
situation of conflict of interest with the Firm for a period of at least two years.

Art. 7

Confidentiality

1. Each Subject respects official secrecy and keeps confidential news and
information learned in the exercise of their duties and which are not subject to
transparency in accordance with the law and regulations.
2. Each Subject observes the duty of confidentiality even after termination of
service.
3. In particular, each Subject does not provide information regarding preliminary
investigations, inspections or investigations in progress at the Firm and does not
release information relating to deeds stipulated or to be stipulated.
4. Each Subject consults only the documents and files to which he is authorized to
access and makes use of them in accordance with his official duties, allowing access
to those who are entitled to it and in compliance with the instructions given in the
Firm.
5. Each Subject prevents the possible dispersion of data by observing the security
measures established, keeping the documents entrusted with order and care and
avoiding making useless copies.

Art. 8

Relations with the press – Accounting transparency and completeness of
information

1. Each Subject does not maintain relations with the press or with other means of
information and abstains from any public statement that could affect the image
of the Firm; if it is requested to provide clarifications or information by the
press or other means of information, it shall promptly notify the owners of the
Firm.
2. Accounting transparency is based on the truth, accuracy and completeness of the
basic information for accounting records.
3. All actions and operations of the Firm must be adequately recorded and it must
be possible to verify the decision-making, authorization and execution process.
4. For each operation, adequate supporting documentation of the activity carried
out is kept in the records, in order to be able to carry out checks at any time
which attest to the characteristics and reasons for the operation and identify the
persons who authorised, carried out , recorded and verified the operation itself.
5. The Recipients are required to provide complete, transparent, understandable
and accurate information, so that in setting up relations with the Firm, the
stakeholders are able to make autonomous and aware decisions of the interests
involved, of the alternatives and of the relevant consequences.

Art. 9

Related activities – Personnel policy

The Firm is committed to creating a serene working environment within it, in which
everyone can work in compliance with the laws, principles and shared ethical values.
The Firm enhances the professionalism of employees and collaborators, supporting
their training, making training tools available to them, trying to develop and grow
specific skills.
It also undertakes to comply with workplace safety legislation and to promote safety
in all places that make up the workplace itself.
– Each Subject informs the owners of the Firm of any writings and articles that it
intends to publish in the fields of competence of the Firm.
– Each Subject does not perform other subordinate or self-employment
activities, including consultancy in matters connected with those of the Firm’s
competence.
– Each Subject does not carry out other external activities which conflict with
the duties or which affect the correct performance of the official duties.

Art. 10

Relations between employees – Collaborators – Owner

Relations between employees, collaborators and the owner must always be based
on the principles of civil coexistence and must take place in mutual respect for the
rights and freedom of individuals.

Art. 11

Relations with the outside world, relations with the public administration,
relations with political organizations and trade unions

Recipients must also comply with the rules of this Code in relations with the outside
world. Relations with public institutions will be held only by persons authorized to
do so.
All relations with the Public Administration must conform to the principles of
diligence, transparency and honesty.
The Recipients of this Code must behave in a manner inspired by the utmost
correctness and integrity in relations with employees and representatives of public
bodies, political forces and trade unions.
Gifts and acts of courtesy and hospitality towards government representatives,
public officials and public employees are permitted only when they are of modest
value and in any case such as not to compromise the integrity or reputation of one
of the parties and cannot be interpreted, as aimed at acquiring advantages
improperly.

Art. 12

Relations with the judicial authorities

In carrying out its activities, the Firm operates in a lawful and correct manner by
collaborating with the Judicial Authorities, the Police Forces and any Public Official
who has powers of inspection and carries out investigations against clients/potential
clients of the Firm while respecting secrecy professional.
The Firm demands that all employees and collaborators are available and
collaborate with anyone who comes to carry out inspections and checks on behalf of
the INPS, Guardia di Finanza, Public Prosecutor’s Office, and any other Public
Administration.
No one should attempt to persuade others to provide false or misleading
information to the proper authorities.

Art. 13

Relations with customers

Relations with customers must be based on loyalty, transparency and
confidentiality, and characterized by courtesy and professionalism, in order to
consolidate the relationship of trust with customers and promote the Firm’s image
with the public.
The personnel, within the scope of their competences, must always keep
themselves informed and updated in order to offer the customer satisfactory
answers and favor informed choices.
In this perspective, it is the Recipients’ responsibility to provide information that is
as clear, complete and understandable as possible to the interlocutor.

Art. 14

Relations with suppliers

The selection of suppliers and the determination of the purchase conditions are
based on an objective assessment of the quality and price of the good or service, as
well as the guarantees of assistance and timeliness.

Art. 15

Sanction provisions

The provisions of this Code are an integral part of the contractual obligations
assumed by the Recipients, or by the subjects having business relations with the
company.
Violation of the provisions of the Code may constitute a breach of contractual
obligations, with all legal consequences, also with regard to the termination of the
contract or of the assignment and any compensation for damages.

Art. 16

Updates of the Code

This Code may be updated on the basis of legislation and ethical principles that have
arisen as well as on the basis of experience acquired from time to time.