SCOPE OF APPLICATION – This Code applies to NeM S.r.l. and its recipients are therefore the members, the members of the statutory bodies, the collaborators / Partners of the Company, the characteristic suppliers who contribute to the value chain, the commercial partners, as well as all those who, directly or indirectly, permanently or temporarily, operate in the name and on behalf of the Company. Customers are required to take note of the adoption of this Code and to commit to respecting the values represented in it, considering this aspect of fundamental importance for the maintenance of the business relationship.

NeM S.r.l. undertakes to disseminate the Code to all interested parties, facilitating its correct interpretation, making available the tools that favor its application and implementation, taking the necessary measures to carry out verification and monitoring activities. Recipients are required to know the rules contained in this Code and the reference standards that regulate the activity carried out in the context of their function, deriving from the law or internal procedures and regulations.

INFORMATION - This Code is brought to the attention of all internal and external interested parties through specific information activities and is published on the Company’s website. In case of request for clarification on the contents of the Code or on the methods of its application, it is possible to contact the following e-mail address:

MISSION – NeM S.r.l. provides professional consulting and auditing services to organizations of different types, with the aim of creating value in full compliance with the ethical principles of the profession. NeM S.r.l. aspires to maintain and develop the relationship of trust with its stakeholders; the ability to effectively pursue our mission is closely connected to the relationships built with them and to the reputation established over time.

REFERENCE PRINCIPLES – The fundamental values of NeM S.r.l. are: Customer focus, Flexibility, Innovation, Teamwork, Sharing, Foresight, Integrity, Compliance with Laws and regulations. It is essential that these values do not remain mere statements but are translated into appropriate conducts and behaviors. The Company aims to be perceived as a serious and reliable professional service Provider, respecting direct competitors, with the ultimate aim of increasing and maintaining the value of the services offered over time.

• LEGALITY – NeM S.r.l. takes as an essential principle the observance of laws, rules and procedures to execute and report business operations, obtain appropriate authorizations and comply with all aspects of internal and external accounting control. To this end, NeM S.r.l undertakes to take useful and appropriate measures so that the constraints of compliance with the laws and all the regulations in force are adopted and practiced.

• RESPECT FOR THE PERSON – NeM S.r.l. – in the context of his own work – ensures respect for the physical and cultural integrity of the person and that of the relationship with others. In particular, it protects and promotes the value of people, in order to improve and increase the assets and the complementarity of the skills possessed by its employees. The Company does not tolerate requests or threats aimed at inducing people to act against the Law or against this Code, or to adopt behaviors that are harmful to the moral or personal beliefs and preferences of each person.

• COMPLIANCE WITH FREE COMPETITION – The Company considers free competition an asset to be protected and recognizes that correct and fair competition affects reputation and is functional to the sustainable development of the company and the market in which it operates. In consideration of this, it refrains from behaviors aimed at favoring the conclusion of business to its advantage in an unfair manner or in violation of laws or regulations in force.

• ENVIRONMENTAL SAFEGUARD – Despite the relatively low environmental impacts associated with its activities, NeM S.r.l. undertakes to analyze its ecological footprint and consequently identify areas for improvement, especially in the rational use of energy resources, that is: careful use of means of transport, optimization of travel routes, reduction of energy consumption, paper and consumables.


• CORRECTNESS AND COMPLETENESS OF INFORMATION – NeM S.r.l. ensures proper information to its members and internal and external control bodies regarding significant facts concerning its corporate management. The financial, accounting and management evidence and any other communication that the Company issues to third parties meet the requirements of truthfulness, completeness and accuracy. It is forbidden to:
– Display facts that do not correspond to the truth;
– Omit information whose disclosure is required by law, on the economic, equity or financial situation of the Company.
In carrying out its activities, in particular with reference to relations with customers, NeM S.r.l. ensures, in addition to the strict observance of applicable laws and regulations, the rigor required by the profession itself.

• TREATMENT AND CONFIDENTIALITY OF INFORMATION – NeM S.r.l. ensures the integrity, availability and confidentiality of the information in its possession, or generated by itself or received from customers and refrains from seeking confidential data through illegal means. The Company has adopted specific instruments aimed at achieving an adequate level of security in the management of the company’s information assets, in terms of:
– Confidentiality (access to information allowed only to authorized persons);
– Integrity (guarantee of accuracy and completeness of the information and of the processing / processing of the same);
– Availability (accessibility to information, by authorized persons, when they need it).

It is primary objective of NeM S.r.l. guaranteeing and protecting the security and protection of data and confidential or personal information relating to collaborators, partners, customers or third parties in their possession. With regard to the use and protection of the information of its customers, the professional ethics obliges the collaborators of NeM S.r.l. to protect the confidentiality of such information both during the assignments and after their conclusion.

• GIFTS, HOMAGES AND OTHER FORMS OF BENEFITS – Free gift forms or benefits are not allowed, promised, offered or received, which can be interpreted as exceeding normal commercial practices or courtesy (for example: homages or gifts of estimated value exceeding € 50.00 shall be not accepted), or in any case aimed at acquiring favorable treatment in the conduct of any transaction attributable to the activity of NeM Srl.

• CONFLICT OF INTEREST – NeM S.r.l., in keeping with the values of honesty, fairness and transparency, undertakes to implement all the necessary measures to prevent and avoid phenomena of conflict of interest. This is especially true when:
– An Interested Party pursues an interest other than the mission of NeM S.r.l.,
– NeM S.r.l. has signed contracts that provide clauses on conflicts of interest.

As a non-exhaustive example, the following situations can determine conflict of interest::
– Use the position in the Company or information acquired in the work so that one can create conflict between his/her personal interests and the interests or pursuit of the Company’s mission;
– Carry out Assessments as a Third Party in the case of recent consultancy assignments at the same organization;
– Make choices, regarding contracts with external parties in various capacities, conditioned by personal interests.

• PROTECTION OF INDUSTRIAL, INTELLECTUAL AND AUTHOR LAW PROPERTIES – NeM S.r.l. undertakes to protect the industrial and intellectual property rights of which it has become aware or to which it has use, and not to unlawfully use assets protected by industrial and / or intellectual property rights.

• HEALTH AND SAFETY – The health and safety of employees is a primary objective for NeM S.r.l., constantly committed to protecting the environment, health and safety in the workplace. Knowledge and observance of the regulations in force on this matter is therefore a priority requirement for NeM S.r.l., for all its collaborators, as well as for contractual counterparties and suppliers. NeM S.r.l. fulfills legal obligations, promoting and spreading the culture of safety, developing awareness of risk management and promoting responsible behavior. In consideration of the fact that NeM Srl, as a provider of Auditing and Consultancy services, carries out its activities with Customers, undertakes to inform itself about the risks – in the field of Environment and Health and Safety – present at their offices and to respect the prescriptions foreseen, with particular regard to PPE (Personal Protective Equipment).

• SUPPLIERS AND BUSINESS PARTNERS – Relationships with Suppliers and Business Partners are based on the search for the right effectiveness / efficiency in supply, loyalty in the relationship, recognition of the professionalism and competence of the interlocutor. NeM S.r.l. undertakes to require its suppliers and business partners to comply with behavioral principles aligned with their own, considering this aspect of fundamental importance for the creation or continuation of a business relationship. Suppliers, Commercial Partners or external collaborators are informed of the existence of the Code of Ethics and the relative commitments and, for this purpose, in the individual contracts there are specific clauses that require or regulate compliance.

• PUBLIC SUPERVISORY AUTHORITIES AND CONTROL BODIES – In communications with Italian State or international institutions, supervisory public authorities or control bodies, in answers to queries, interpellations, requests for information related to ongoing or completed professional assignments, etc. , or however in making known the position of NeM Srl on relevant issues, the Company adheres to the principles of transparency and professional fairness. More specifically, it undertakes to:
– Adopt an attitude of maximum availability and collaboration and not knowingly hinder in any way the functions performed by the subjects indicated above;
– Operate through the communication channels set up for this purpose with the institutional interlocutors at national and international, community and territorial level;
– Represent their interests and positions in a transparent, rigorous and consistent manner, avoiding collusive attitudes.