PREAMBLE
- A) SENESIDESIGN S.r.l.(hereinafter referred to simply as “SENESIDESIGN” or “Company”) is a family company operating as an integrated communication agency, with its legal and operational headquarters in Milan, Via Cesare Ajraghi n. 26.
Founded in 1980 by Corrado Senesi, later joined by his sister Barbara, SENESIDESIGN has collaborated since its inception with some of the most important multinational companies in the consumer goods sector, consistently making innovation and service quality the pillars of its growth over the years.
Now led by the second generation, Tatiana Furlanetto (daughter of Barbara) and Luca Senesi (son of Corrado), the Company relies not only on a well-established and experienced internal team but also on a carefully selected and tested network of external suppliers to ensure the optimal execution of its creative projects.
Given the above, SENESIDESIGN is committed to promoting and ensuring the proper application of this Code of Ethical Conduct (the “Code of Ethics”) among its employees and partners.
Any behavior contrary to the provisions of this Code will be identified and corrected as it contradicts the Company’s principles.
SENESIDESIGN will oversee compliance with the rules contained in the Code of Ethics, ensuring transparency in corrective actions in case of violations.
- B) Guiding Principles of SENESIDESIGN S.r.l.’s Activities
This document outlines the commitments and responsibilities that all SENESIDESIGN employees, administrators, and third-party collaborators must adhere to in conducting and managing business activities.
- C) SENESIDESIGN S.r.l.’s Mission
The primary mission of SENESIDESIGN is to create and finalize projects related to Brand Identity, Packaging Design, Shape Design, Concept Design, Key Visuals, BTL and POS Material, Video, and Digital, as well as any activities connected to these services.
- D) Reputation, Fiduciary Duties, and the Value of Reciprocity
SENESIDESIGN, aware of the essential and irreplaceable value of reputation, is committed to maintaining ethical conduct with all its stakeholders, ensuring a moral approach in its decision-making processes.
The Company recognizes the significance and impact of its business decisions on the broader community. Therefore, it seeks and encourages social approval by attracting top talent and valuing their contributions, ensuring customer satisfaction, maintaining trust and reliability with suppliers and third parties, and showing respect and consideration towards national and regional communities with which it interacts.
This Code is thus designed to protect mutual respect among all involved parties and prevent behaviors inconsistent with the Company’s ethical vision.
SENESIDESIGN requires its stakeholders to adhere to principles and rules aligned with a similar ethical standard and in full compliance with current laws and regulations. Those who do not have such standards in place are expressly invited to adopt their own Code of Ethics.
INTRODUCTION
1.1 General Ethical Principles
SENESIDESIGN intends to operate according to the ethical principles set forth below and will strive to ensure that these same principles guide the actions of its partners.
This Code of Ethics aims to facilitate the dissemination and internalization of these principles within the Company while serving as a distinctive and identifying element of the Company in the marketplace and with third parties engaging with it.
- A) Compliance with Laws, Honesty, Integrity, and Whistleblowing Compliance
SENESIDESIGN is committed to conducting its activities in full compliance with European, national, regional, and international regulations, rejecting corruption and all illegal practices, and making every effort within its means to support initiatives aimed at fighting crime and terrorism. No behavior that contradicts European, national, regional, or international law, this Code of Ethics, or internal policies will be justified, even if motivated by a supposed Company interest, and will result in corrective actions by SENESIDESIGN.
Executives, employees, and all individuals engaged with the Company, including consultants, partners, and occasional collaborators, are required to comply with applicable national, European, and regional laws, as well as SENESIDESIGN’s internal regulations and codes.
The Company has implemented a communication platform in accordance with the provisions of whistleblowing regulations (Legislative Decree 24/2023), reaffirming its commitment to protecting employees and collaborators who report violations.
- B) Diligence and Accuracy in Professional Services
SENESIDESIGN considers it of fundamental importance to provide high-quality services to its clients and other business partners. Employees and collaborators must act diligently, accurately, and professionally to deliver services of the highest standard.
- C) Transparency and Completeness of Information
SENESIDESIGN prioritizes providing clients and third parties with precise, clear, and complete information to ensure maximum transparency in business relationships.
Employees and collaborators must make every effort to understand client needs and offer products and services that meet those needs effectively.
- D) Impartiality and Non-Discrimination
The Company upholds impartiality as a fundamental value in all internal and external relations. SENESIDESIGN does not tolerate any form of discrimination based on nationality, health status, age, gender, religion, moral beliefs, sexual orientation, political opinions, or any other factor. To reinforce this commitment, the Company has obtained the UNI/PdR 125:2022 certification for gender equality.
Employees and collaborators must adhere to impartiality standards in all professional interactions, ensuring fair treatment based on technical and professional assessments.
- E) Democratic Principles and Individual Respect
SENESIDESIGN values the dignity, rights, and freedoms of all individuals. Employees and collaborators are free to express their ideas and beliefs, provided they respect Company policies, the rights and dignity of others, and workplace harmony.
In all professional interactions, employees and collaborators must exhibit respect for individuals, their autonomy, and their rights. The principles of fairness, cooperation, loyalty, and mutual respect must also be upheld in dealings with external parties.
- F) Fair Competition
SENESIDESIGN operates in compliance with fair competition principles, which it considers essential for market development and customer satisfaction.
- G) Company Image
SENESIDESIGN considers its image and reputation to be valuable assets that must be protected and enhanced through adherence to the ethical principles outlined in this Code.
Employees and collaborators must refrain from any behavior that could harm the Company’s reputation.
- H) Transparency, Consistency, and Verifiability of Activities
All agreements, transactions, and operations carried out by SENESIDESIGN must be verifiable and consistent with the Company’s objectives.
Decisions and actions taken on behalf of the Company must be documented and traceable to ensure accountability.
1.2. Recipients of the Code of Ethics
The principles and provisions of the Code of Ethics apply to the Company’s employees and all those who cooperate in pursuing the Company’s objectives within the relationships they maintain with the Company itself. The top management of SENESIDESIGN adheres to the principles of the Code of Ethics, as indicated above and further detailed below, in every decision or action related to the Company’s management. Likewise, officials and supervisors are responsible for concretely implementing the Company’s management activities. Employees and all those who engage in business or collaborative relationships with SENESIDESIGN (such as consultants, legal advisors, etc.) are required to align their behavior with the provisions of the Code of Ethics, which must be appropriately communicated to them and duly signed.
The principles and provisions of the Code are binding, without exception, for all individuals professionally linked to SENESIDESIGN through employment and/or collaboration, as well as for those who, directly or indirectly, establish stable or temporary relationships with SENESIDESIGN.
SENESIDESIGN informs the individuals mentioned in the previous paragraph about this Code of Ethics and commits them to its compliance.
1.3. Value of the Code of Ethics
Compliance with the rules contained in the Code of Ethics must be considered an integral and essential part of the contractual obligations for the Company’s employees and all collaborators.
Likewise, compliance with these rules must also be regarded as an integral and essential part of the contractual obligations for non-subordinate collaborators. The Company will require the inclusion of a specific contractual clause to this effect in agreements, if missing, in both existing contracts at the time of the Code’s dissemination and in future contracts.
Violation of these rules will constitute a breach of the obligations arising from employment or collaboration agreements, with all legal and contractual consequences.
In particular, non-compliance with the rules and regulations of the Code of Ethics by employees and/or company administrators will be considered a liability for the offender and, in accordance with SENESIDESIGN’s disciplinary system, may lead to the application of appropriate sanctions.
Furthermore, violations of the rules and regulations contained in the Code of Ethics by the Company’s business partners, suppliers, or consultants may constitute just cause for contract termination.
2. APPROACH AND RELATIONSHIP WITH CLIENTS: BEHAVIORAL CRITERIA
2.1. Client Relations
In managing client relationships, employees and collaborators must strictly comply with legal provisions and the hiring procedures and regulations established by the Company, avoiding any conflict of interest with the Company in any way.
In general, employees and collaborators must refrain from any behavior that allows, directly or indirectly, even potentially, the gain or attribution of economic advantages through procedures that do not comply with corporate policies. The Company pays the utmost attention to providing clients with a service characterized by fairness, efficiency, competence, and professionalism. Employees and collaborators are required to maintain a conduct in client relations that aligns with these principles to understand their needs and seek appropriate solutions.
2.2. Managing Accounting Activities
In the accounting of transactions related to the management of the Company, employees and collaborators are required to strictly comply with applicable regulations and internal procedures to ensure that each operation is not only correctly recorded but also authorized, verifiable, legitimate, consistent, and appropriate.
2.3. Internal Control
SENESIDESIGN has always promoted and intends to continue promoting a culture of control and raising employee awareness of the importance of the control system and compliance with current regulations and corporate procedures in the execution of business activities by employees and collaborators.
The Company is committed to ensuring that the organization and activities of internal control personnel operate with the highest degree of autonomy and consistently align with the most advanced standards. Employees and collaborators in the internal control function must conduct themselves in accordance with the principles of confidentiality, autonomy, independence, integrity, and the absence of conflicts of interest, while respecting individual rights. They must also demonstrate loyalty and adherence to the specific Code of Ethics adopted by the internal control function.
Employees and collaborators of the Company are required to cooperate to ensure the proper and efficient functioning of the internal control system, actively participating in reporting situations relevant to the control function and promoting the principles advocated by this function.
Within SENESIDESIGN, an internal reporting system is in place to allow the reporting of acts or facts that may constitute violations of regulations governing industrial activities or other unlawful conduct (whistleblowing system). The system ensures maximum confidentiality when reporting violations that could harm the integrity of SENESIDESIGN, protecting whistleblowers from potential retaliatory or discriminatory actions.
2.4. Managing Informational Elements
SENESIDESIGN has the direct responsibility to promote, verify, and continuously maintain its personnel’s awareness of the proper management of information and documents.
2.5. Relations with Other Companies
SENESIDESIGN intends to conduct its relationships with other companies in full compliance with competition and market regulations, based on fairness and good faith.
2.6. Relations with Regulatory and Supervisory Authorities
SENESIDESIGN is committed to conducting its relations with regulatory and supervisory authorities with the highest level of cooperation, fully respecting their institutional role, and ensuring prompt implementation of their directives.
2.7. Transparency, Completeness, Confidentiality of Information, and Privacy Protection
SENESIDESIGN is committed to reviewing and managing the flow of information it acquires in the course of its activities, ensuring that such information meets the criteria of truthfulness, completeness, and accuracy.
Anyone within SENESIDESIGN, or in the context of dealings with it, who has access to confidential information and data must strictly comply with applicable laws and use such data only for legally permitted purposes.
Through its employees and collaborators, SENESIDESIGN is committed to protecting the confidentiality and privacy of information and data belonging to employees, collaborators, or third parties, collected in the course of work-related activities. The Company’s governance bodies, management, employees, and collaborators are required not to disclose such information to third parties unless explicitly authorized by the concerned party and the designated corporate officer.
No employee or collaborator may derive any direct or indirect, personal, or financial advantage from using such information unless it is already public knowledge.
Each employee is responsible for protecting and managing information stored on electronic, magnetic, and/or paper-based media in compliance with internal regulations and procedures.
2.8. Anti-Money Laundering
Employees and collaborators of SENESIDESIGN are required to comply with all national and international laws and regulations, as well as internal procedures, concerning anti-money laundering.
3. INSTRUMENTAL AND COMPLEMENTARY ACTIVITIES: BEHAVIORAL CRITERIA
3.1. Employee Relations
SENESIDESIGN ensures the widest dissemination of the Code of Ethics among its employees.
Employees must be familiar with and adhere to the provisions of the Code of Ethics, and, within their capabilities, promote its knowledge among newly hired employees and third parties affected by the application of the Code with whom they interact in the course of their duties.
Employees are required to report to the Supervisory Body, as outlined in paragraph 6.1, any violations of the Code of Ethics committed by colleagues, collaborators, and consultants. The Company will consider any false reports made in bad faith, including those intended to harm colleagues or collaborators, as a disciplinary offense.
In any case, SENESIDESIGN, in line with its commitment to transparency and legality, requires that employees, when necessary, use the channels provided by the Corporate Plan for the Prevention of Offenses (Whistleblowing) to report inappropriate conduct and behavior that does not comply with the ethical principles of the Code of Ethics carried out by employees and/or collaborators of the Company.
A) Selection and Advancement
SENESIDESIGN places the utmost and continuous attention on the development of human resources, considering them a fundamental asset for the Company’s sustained success and quality. The Company values meritocracy, professional competence, honesty, and integrity in behavior.
From this perspective, the selection of personnel must be based on the candidates’ alignment with the Company’s technical and professional requirements.
SENESIDESIGN opposes, rejects, and condemns the use of personnel selection and hiring for personal favors or the granting of privileges.
SENESIDESIGN also strongly opposes and rejects any form of discrimination in both the selection and hiring of personnel, as well as in employment relationships, based on gender, religion, age, race, social status, or nationality of candidates or employees. The Company ensures equal opportunities for all employees and actively works to remove any barriers to achieving such conditions.
B) Education, Training, and Professional Development
SENESIDESIGN is committed to promoting within the company and among individuals with whom it maintains stable or occasional relationships the principles outlined in this Code of Ethics, as well as spreading awareness of applicable laws and regulations.
SENESIDESIGN places great emphasis on enhancing the professional skills of its employees and on implementing training initiatives aimed at acquiring essential professional knowledge and updating existing competencies. Employees represent the image of the Company and must always be aware of the potential impact of their behavior on this fundamental value, both for the Company itself and for their colleagues.
- C) Work Environment and Interpersonal Relationships: Dignity, Health, and Safety of Workers
SENESIDESIGN is deeply committed to ensuring workplace safety and adequacy.
The Company guarantees working conditions that respect individual dignity, professionalism, and autonomy, in compliance with legal requirements and collective labor agreements.
SENESIDESIGN ensures safe and healthy working environments through:
- An integrated risk management system and control of work methodologies consistent with and compliant with the provisions of Legislative Decree 81/08;
- Training programs and communications aimed at spreading a corporate culture of safety.
SENESIDESIGN is also committed to protecting the physical and psychological well-being of employees while respecting their individuality. Employees must always conduct themselves in a manner that respects the rights and personalities of colleagues, collaborators, and third parties. Supervisors are required to exercise their authority with fairness and impartiality, maintaining exemplary adherence to corporate regulations and this Code of Ethics, to encourage a culture of respect and professionalism among subordinates.
Furthermore, SENESIDESIGN is in the process of adopting an update to its corporate regulations, which will prohibit employees from consuming alcohol and drugs before and during work to safeguard both individual and collective safety.
D) Use of Company Assets
Employees must properly use the company assets provided to them, exercising the utmost care and attention in compliance with, within their responsibilities, hygiene and workplace safety regulations, while generally safeguarding the value of corporate assets.
3.2. Relations with Collaborators and Consultants (Contract Workers, Experts, Legal Advisors, etc.)
Collaborators and consultants of SENESIDESIGN, in executing their contractual relationship with the Company or any assignments received from it, must act with integrity, good faith, and loyalty, complying—where applicable—with the provisions of this Code of Ethics, corporate regulations, and instructions provided by the Company’s personnel.
A) Establishment and Execution of the Relationship
SENESIDESIGN considers it an essential requirement for the establishment and continuation of relationships with collaborators and consultants that they comply with applicable regulations and the principles set forth in the Code of Ethics while performing their professional duties.
SENESIDESIGN selects collaborators and consultants with absolute impartiality, autonomy, and independence of judgment, without accepting any influence or compromise of any kind aimed at creating favorable or privileged situations for third parties or obtaining favors or advantages.
In selecting collaborators and consultants, the Company carefully evaluates their professional competence, reputation, independence, organizational skills, and ability to properly and punctually fulfill their contractual obligations and assigned tasks.
B) Relevance and Knowledge of the Code of Ethics
SENESIDESIGN requires that every individual agreement with collaborators or consultants include compliance, within their respective scope, with the Code of Ethics. The Company also ensures the direct dissemination of the Code of Ethics to collaborators and consultants, who are required to adhere to the principles contained within it.
Behaviors that contradict the principles expressed in the Code of Ethics may be considered by the Company as a serious breach of the duties of integrity and good faith in contract execution, constituting grounds for a breach of trust and just cause for termination of contractual relationships.
C) Conduct in the Execution of the Contractual Relationship
Collaborators and consultants must avoid any situation of conflict of interest with the Company during the execution of their professional duties. In case of conflict, they must immediately report it to their business contacts and refrain from executing the task unless otherwise instructed by the Company.
Every collaborator or consultant must, under no circumstances, engage in any act that is or may be considered illegal, even if such behavior could theoretically bring an advantage to the Company.
Each collaborator or consultant is responsible for protecting and enhancing the image and reputation of the Company through conduct that reflects professionalism, personal care, civility, and respect for others.
Collaborators and consultants must properly use and safeguard the integrity of any company assets provided to them.
3.3. Relations with Suppliers
In the procurement of goods and services, SENESIDESIGN adheres to the principles of this Code and internal procedures.
SENESIDESIGN bases its relationships with suppliers on the principles of fairness and good faith, as well as compliance with competition and market regulations.
In this context and in compliance with these rules, employees involved in supplier relations must conduct the selection process based on quality, price, cost-effectiveness, capability, and efficiency, or other predefined and objectively measurable criteria, ensuring impartiality and transparency. Supplier selection must align with the company’s commercial and business policies and always consider the honesty and integrity of the chosen supplier.
Employees and collaborators must avoid any conflict of interest, even potential ones, regarding suppliers and must report any existing or emerging conflicts to the Company.
Employees, collaborators, and administrators of SENESIDESIGN are prohibited from accepting gifts or benefits from suppliers, except for those that fall within customary business courtesies and are of modest value.
3.4. Relations with Business/Negotiation Partners
SENESIDESIGN ensures that commercial and negotiation partners share the principles of the Code of Ethics and requires their compliance throughout the entire relationship.
Association agreements with partners must be formalized and clearly outline the relevant conditions.
4. THIRD PARTIES AND THE COMMUNITY: BEHAVIORAL CRITERIA
4.1. Relations with the Community (Environmental Policy, Sustainable Development, Non-Profit Initiatives, Sponsorships for Cultural and Sports Initiatives)
SENESIDESIGN places great importance on respecting the interests of the community and considers it a duty for everyone to collaborate in improving the quality of life and social well-being.
SENESIDESIGN regards the environment and nature as fundamental values and shared heritage that must be protected and preserved. To this end, it is fully committed to conducting its activities in alignment with these principles.
SENESIDESIGN operates in a way that avoids harming the environment and adopts measures to promote sustainable development, also considering ethical responsibility.
4.2. Relations with Political and Trade Union Organizations
SENESIDESIGN does not provide any contributions, directly or indirectly, to political parties, movements, committees, or political and trade union organizations, nor to their representatives or candidates, except in the forms and methods permitted by applicable regulations.
4.3. Relations with the Press and Other Mass Media
SENESIDESIGN interacts with the press and mass media exclusively through the corporate bodies and business functions delegated for this purpose, maintaining an approach of utmost correctness, availability, and transparency, in line with the Company’s defined communication policy.
Employees are prohibited from providing information to mass media outlets unless they have been specifically and previously authorized by the competent corporate functions. This measure also ensures compliance with NDAs signed with third parties.
The Company opposes and rejects any form of misinformation or inaccurate and imprecise dissemination of news regarding the Company and its activities. It takes all necessary actions to protect its image and ensure the accuracy of information about itself.
In all cases, information and communications concerning the Company intended for external parties must be accurate, truthful, complete, transparent, and consistent with one another.
5. CORPORATE COMMUNICATIONS AND INFORMATION FLOW: BEHAVIORAL CRITERIA
5.1. Obligation to Cooperate
Employees and/or administrators of SENESIDESIGN must cooperate with the Company’s internal supervisory bodies, providing all requested information.
5.2. Internal Information Flow at SENESIDESIGN s.r.l.
SENESIDESIGN administrators must, in compliance with the law, the Company’s Statute, and internal regulations, properly inform shareholders about the company’s progress and activities.
All individuals operating in the interest of SENESIDESIGN or in collaboration with it must provide any information requested by the Company’s governing and/or supervisory bodies.
5.3. Transparency in Corporate Communications
Financial statements, semi-annual or annual reports, and all other corporate communications must be drafted clearly and accurately represent the Company’s economic, asset, and financial situation.
In these communications, the presentation of false material facts and the omission of legally required information that could significantly alter the Company’s economic, asset, and financial situation or mislead the recipients of such communications is strictly prohibited.
5.4. Obligation to Cooperate with Control and Supervisory Bodies
All employees and/or executives of SENESIDESIGN must collaborate with the Sole Auditor or the auditing firm, providing the information, clarifications, and documents requested.
6.SUPERVISION OF THE APPLICATION OF THE CODE OF ETHICS AND CONSEQUENCES OF ITS VIOLATION
SENESIDESIGN, in adopting the Code of Ethics, has delegated the verification of compliance to the President of the Board of Directors, who has the authority for initiative and control in this regard.
This body has been entrusted with the task of monitoring the functioning and compliance with the Organization and Management Model and updating it as necessary.
Additionally, it is responsible for promoting the dissemination and understanding of the Code of Ethics, ensuring its application and updates, and taking action—either proactively or upon notification—to prevent or address any violations through the appropriate corporate functions.
Any information and reports received, either independently or via notification, that are submitted in written form to the supervisory body or its designated structures will be considered confidential and cannot be disclosed except as required by applicable law.
6.2. Consequences of Code Violations for Employees
Failure to comply with or violation of the behavioral rules imposed by the Code of Ethics and corporate procedures by company employees constitutes a breach of contractual obligations and a disciplinary offense.
Regarding the applicable sanctions, they will be imposed in compliance with the procedures established by the current National Collective Labor Agreement (CCNL).
These sanctions will be applied based on the severity of each specific case and will be proportionate to its gravity. The determination of such violations, the management of disciplinary proceedings, and the imposition of sanctions remain the responsibility of the corporate functions designated for this purpose.
6.3. Consequences of Code Violations for Executives and Administrators
In the event of a violation of internal procedures and the Code of Ethics by executives, the Company will evaluate the facts and behaviors and take appropriate actions against those responsible.
If an executive-level individual at SENESIDESIGN violates the Code of Ethics, the Supervisory Body will inform the administrative body, which will take the necessary actions in accordance with the law.
6.4. Consequences of Code Violations for Collaborators, Consultants, and Other Third Parties
Any misconduct committed by collaborators, consultants, or other third parties associated with SENESIDESIGN through a non-employee contractual relationship that violates the provisions of the Code of Ethics may result in the termination of the contractual relationship, as outlined in the specific contractual clauses of their agreements.
Even in the absence of explicit contractual clauses, the Company reserves the right to terminate the relationship and seek compensation for any damages incurred due to such misconduct, regardless of whether the contract is terminated.