Professionals and companies operating in a complex and challenging economic reality, both locally and internationally, must necessarily identify, share and maintain firm principles, from which to draw constant orientation and inspiration.
It is not only the profit that counts but also, and above all, how it is achieved. In Libra we believe that real profit consists in the value generated by fulfilling one’s duties with competence and professionalism, in compliance with fundamental ethical values.
Such values may only be shared and identified starting from the People who represent Libra. As professionals, we are aware that the opportunities arising from our activity must necessarily entail great responsibility.
For this reason, the present Code of Conduct intends to state not only the ethical principles that guide us in fulfilling our duties but also the values that inspire the philosophy and vision of Libra.
Art. 1 – Scope of application
Recipients of the present Code of Conduct shall mean salespeople, consultants, employees, trainees and interns, as well as external collaborators, lawyers and partners at Italian and foreign offices, and any other professional who acts in the field, in the name and on behalf of or otherwise in connection with Libra.
All recipients shall observe the principles and values contained in the present Code of Conduct within the scope of their tasks and responsibilities, acknowledging that compliance with the present Code of Conduct is an essential part of one’s working responsibilities.
Art. 2 – General principles
All Recipients shall act in compliance with the present Code of Conduct, with the relative regulations of Italy and of every other country they may operate in.
All recipients shall act in compliance with the highest standards of ethical conduct and in sharing Libra’s values. All recipients shall also perform their duties in compliance with the principles of competence, diligence, correctness, honesty, loyalty and confidentiality.
Art. 3 – Principles of diligence and competence
Recipients shall fulfill their duties with diligence, professionalism and in an appropriate manner with respect to their duties and area of practice. Each Recipient shall keep up-to-date and undertake continuous professional training, with the aim of increasing their competence with particular reference to the areas of their own practice.
Art. 4 – Principles of correctness, honesty and loyalty
All Recipients shall operate in accordance with the principles of fairness, honesty and loyalty both in internal and external relationships, refraining from conducts that could damage the prestige and reputation of Libra, favor illicit conduct, collusive conduct or requests for personal advantages.
In particular, conducts aimed at paying or offering, directly or indirectly, payments, benefits or other advantages to entities or companies, public officials and public or private employees, to influence or compensate for the obtaining of offices or acts in favor of Libra are prohibited.
Acts of courtesy, made or received, such as gifts or forms of hospitality, are permitted only if 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 undue advantages.
Art. 5 – Duty of confidentiality and protection of privacy
Recipients shall maintain the utmost confidentiality with regard to any information they may acquire in the exercise of their professional activities and shall not disclose by any means any information with regard to customers or to any of the tasks entrusted to Libra, except information that is publicly available or that is required to be disclosed by any regulatory authority in the lawful and appropriate exercise of its jurisdiction.
Recipients shall comply with the obligation of professional secrecy and to ensure the utmost confidentiality in relation to news and information directly or indirectly acquired from parties and subjects with whom they come into contact in the context of their professional activity, in compliance with the legal regulations in force and those expressly provided for the processing of personal data.
Libra performs all the necessary activities to comply with current privacy regulations in the exercise of professional activity.
Art. 6 – Compliance
Recipients shall comply with current regulations and Libra directives on anti-money laundering and insider trading.
The Recipients do not use confidential information to which they have access in order to carry out operations of any nature, directly or indirectly, at their own risk and for their own account or at the risk or on behalf of third parties.
Art. 7 – Shared values in internal relationships
In Libra we are firmly convinced that the added value is created by the People, without discrimination based on sex, age, race, religion, sexual or political orientation.
Each Person is seen as a Professional in their own area of practice; as such, every Person is encouraged to pursue constant improvement, knowledge and competence in their own are of practice.
Transparency, consistency and a sense of belonging to Libra are three key values that inspire the relationships between the People in Libra. We believe in developing a collaborative, stimulating and reliable work environment. All Recipients shall collaborate in the training of trainees according to the guiding values and in compliance with current ethical and legal obligations, and in compliance with internal procedures.
All Recipients shall use the goods, equipment and functional equipment for carrying out professional and work activities, where provided by Libra Srl, with the utmost care and diligence, in compliance with the principles of solidarity and sustainability.
Art. 8 – Violation of the provisions of the Code of Ethics
Sharing these principles and values shall mean creating a stronger bond with one’s clients and colleagues. Failure to comply with this Code of Conduct — without prejudice to the sanctions provided for by law and/or professional associations — shall be regarded as violation of the relationship of trust with Libra, which may consequently adopt adequate and proportionate measures against the Recipient responsible for the misconduct.
Milan, 16th of October 2020
