Ethical Code

ASSYSTEW Associates are required to strictly comply with the Association's Code of Ethics. Any failure to comply with the Code of Ethics will result in the case being examined by the Board and the possible adoption of disciplinary measures by ASSYSTEW.


ASSYSTEW ETHICAL CODE

1. Introduction

• Foreword.

• Purpose of the Code of Ethics.


2. Ethical principles

• General ethical principles.

• Ethical principles in the context of corporate governance.


3. Conduct criteria

• Relationships between members and between members and the Association.

• Relationships with customers and institutions.


4. Methods of implementing the Code of Ethics Internal control system

• Sanction system.

• Entry into force, effectiveness, updating and amendments.


1. Introduction

ASSYSTEW is a free, non-recognized, non-profit association that deals with supporting and sustaining the professional and personal growth of seafarers, who work on board yachts in the interior department as stewards and stewardesses; taking care of the interests, exclusively by making the operational characteristics and any related problems known to the Associates without representing the same associates either legally or unionically, at any competent Italian and international body, institutional and otherwise, also in order to facilitate the development of an adequate regulatory context for the sector; promoting and encouraging the exchange of experiences and information among the Associates, as well as between them and other institutions; promoting the activity of the Associates with Italian and international operators in the maritime sector, facilitating collaborative relationships.

This Code of Ethics (hereinafter also the "Code") is an expression of the ethical principles and values ​​adopted by the Associates and Collaborators (intended as all members of the statutory bodies, any external collaborators and those figures who, by virtue of specific mandates or powers of attorney, can represent the Association towards third parties) of ASSYSTEW, as well as by those who, in various capacities, work towards the achievement of the objectives of the Association itself.

This Code defines the measures that the Association intends to adopt from an ethical-behavioral perspective and prepares the internal and external lines of conduct for the same, with the aim of ensuring that its Associates and Collaborators, both within the context of the association's life and in carrying out their specific activity, are subject to certain common rules of conduct, and that their actions are aligned with principles of fairness and correctness, to guarantee transparency, correctness and professionalism, as well as to the benefit of the entire system. Furthermore, together with the Statute, it constitutes an element of mandatory acceptance for membership and registration in the Association.

The Code of Ethics is composed as follows:

• general principles: the values ​​considered fundamental, shared and recognized by ASSYSTEW for the affirmation of its purposes, which the various parties involved are required to aspire to in order to promote the good functioning, reliability and reputation of the Association;

• conduct criteria: they provide the guidelines and rules to which Collaborators, Consultants, Partners, Associates and those who, in various capacities, collaborate in the achievement of the objectives of ASSYSTEW are required to comply with in order to respect the general principles and to prevent the risk of unethical behavior, meaning, in a non-exclusive or exhaustive manner, all those behaviors to the detriment of the good name of the Association and its Associates;

• implementation methods: they describe the control system for compliance with the Code, the sanctioning system and the mechanisms designed to guarantee its effectiveness and continuous improvement.

Purpose of the Code of Ethics

The decision to provide the Association with a Code of Ethics is driven by the belief that the correct application of the rules contained therein can contribute to improving the behavior of the subjects to whom it is addressed. The Association has therefore defined a series of fundamental values ​​and principles that inspire the behavior of all those who work with/for the Association.

Everyone, from the individual Associate to the highest levels of the association, must participate and be involved in the pursuit of the objectives and in compliance with the relative implementation methods, as each individual unethically correct behavior not only causes negative consequences within the association, but damages the image of the entire category, in the eyes of public opinion, the legislator and the Public Administration. The Code contains the set of principles and rules of ethics and conduct that each member and those who hold association positions are required to observe and which they must be inspired by in the exercise of their activity.

Violation of the principles and rules contained in this Code is sanctioned in accordance with the terms set out in the Statute, unless it constitutes conduct having criminal relevance.

By being part of ASSYSTEW, members undertake to take into account, in all their professional and associative behavior, the repercussions on the entire category. Therefore, as members, they undertake, not only towards the Association:

• to apply and observe the provisions of the law, the Statute and any internal regulations;

• in the context of their activity on board, to behave with fairness and correctness towards their collaborators, encouraging their professional growth, promoting mutual support and safeguarding safety at work;

• always in the context of their activity on board and the associative life, to adopt a professional and correct attitude towards colleagues, the managers of their department and guests on board; more generally, to maintain relationships inspired by correctness and integrity;

• again, in general, to consider the protection of the environment and the sea and the prevention of all forms of pollution a constant commitment.

As members they undertake:

• to participate in the associative life of ASSYSTEW;

• to contribute to the associative choices in full integrity and autonomy from internal and external pressures, having as a priority objective the interest of the entire category and of the Association;

• to respect any directives that the Association, through the Board of Directors, should provide in the areas in which it operates, as well as to express personal positions in advance in the appropriate internal debate forums.

The Code also establishes reference standards and rules of conduct that must guide the behaviors and activities of those who operate within ASSYSTEW: the ethical principles contained within the Code are, therefore, intended to bind the behaviors of all those who operate within the Association or who interact with it and, therefore, to discourage the members of the Association from engaging in behaviors that are in contrast with the inspiring principles of cooperation.

ASSYSTEW undertakes, and through it all Associates undertake, to respect and transparently implement the behavior models inspired by autonomy, integrity, ethics and to develop coherent actions. The Association confirms - also through this document - the desire to express its ethics in the pursuit and achievement of its statutory purposes and social objectives as well as for the continuous enhancement of the Association's initiatives.

Those who operate within the Association therefore undertake to respect the principles and provisions contained in this Code, as well as in other ethical-behavioral policies adopted by the Association.

By providing adequate information, prevention and control tools, ASSYSTEW guarantees the transparency of the conduct implemented, intervening, where necessary, to repress any violations of the Code and will monitor its effective observance.

2. Ethical Principles

General Ethical Principles

Legality

The Recipients are required to strictly comply with the laws and, in general, with the regulations in force, both national and EU. Furthermore, they are committed to complying with any regulations, procedures and instructions in force in the sector of reference, as implementations of regulatory obligations.

Correctness and Integrity

The Association considers the observance of the values ​​of honesty, loyalty, correctness and compliance with the laws as an essential basis for its actions and requires that these ethical principles inform the actions of all recipients of the Code.

The utmost rigor is observed in the management and use of the Association's financial resources.

The Recipients are also required to comply with the internal regulations of the Association, as an expression and implementation of general ethical obligations of correctness and integrity, in all relationships with people or entities internal and external to the Association.

Cooperation, collaboration, support and participation

The Associates undertake to collaborate and cooperate with each other while respecting their respective skills, professionalism and diversity, to the point of hypothesizing integrated solutions of mutual support.

Constant and constructive participation in activities (events, meetings and the like) is fundamental, which can lead to a positive and rewarding dialectical comparison on all issues of common interest.

Transparency

The Recipients are required to respect the principle of transparency, understood as clarity, completeness and relevance of information regarding the social activity and, in particular, that relating to the management and use of financial resources, both internally and externally.

Confidentiality

The Recipients ensure the maximum confidentiality of information classified as secret or confidential that may be known during the activities carried out within the context of the association's life or on behalf of the Association. In general, they are required to process data and information exclusively within the scope and for the purposes of work activities and, in any case, not to disclose (communicate, disseminate or publish in any way) sensitive information without the explicit consent of the interested parties, whether it is the Association itself, other Associates, or any other external entity.

The Association also requires that the information obtained within the scope of association life is not used for its own interests in order to gain undue advantage in ways that are contrary to the law or in a way that causes damage to the rights, assets and objectives of the Association.

Excellence

The Recipients, in particular the Associates, consider ASSYSTEW a tool for cultural and professional improvement, implementing and continuously developing the fruitful exchange of knowledge and experiences: the Association's objective must be the creation of value, culture and content, in order to offer concrete and continuous support to Associates, maritime workers, professionals in the yacht interiors department.

Expertise

In pursuing its goals, ASSYSTEW works continuously to equip itself with an ever-increasing wealth of knowledge, skills and experiences: to this end, it is committed to promoting initial and continuous training initiatives aimed at Associates and the wider public, also in collaboration with other institutions, both public and private. The opportunity to establish selection principles for the entry of new members will also be taken into consideration in order to ensure verification of the possession of professional and experience requirements in line with the objectives of the Association, including the sharing of the principles expressed in this Code, such as attention to support, solidarity, social issues and environmental protection.

Independence

In pursuing the association's objectives, ASSYSTEW does not accept or tolerate external conditioning of any kind.

Value of the person and mutual respect

ASSYSTEW promotes the use of human resources in respect and valorization of individual characteristics, protecting diversity and basing internal relations mainly on dialogue.

Respect for the dignity of the person: the Recipients respect the fundamental rights of people by protecting their moral integrity and guaranteeing equal opportunities.

In internal and external relations, behaviors that have a denigratory and/or discriminatory content, i.e. based on political and trade union opinions, religion, racial or ethnic origins, nationality, age, sex, sexual orientation, state of health and, in general, any intimate characteristic of the human person, are not permitted.

Responsibility of Associates

The Associates, first and foremost, recognize the aforementioned principles and undertake to respect them. They are ethically responsible to each other and to the Association for the application of these principles.

Protection of the name

The Recipients must not commit actions that may endanger or compromise the values, image and good name of ASSYSTEW and its purposes. They are also required to use the association logo, avoiding any method that is not in accordance with the association's purposes or that may in any case cause damage to the prestige and good name of the Association itself.

Promotion of the Association

In the organization and implementation of those initiatives and activities (such as events, meetings or debates) which, as provided for in the Statute, allow the achievement of the Association's purposes (in particular, but not limited to, that of "supporting the professional growth of maritime stewards/ess, who work on yachts", that of "promoting and encouraging the exchange of experiences and information among the Members, as well as between them and other institutions", as well as that of "representing the Members at every competent Italian and international body, institutional and otherwise, also in order to facilitate the development of an adequate regulatory context for the sector"), particular importance is given to respecting the individual position of each Member and, at the same time, the recognition by each individual Member of the strategic role assumed by the Association, as the body promoting the aforementioned initiatives and activities.

For these reasons

• events, meetings and debates must be held ensuring, as far as possible and even if only potentially, visibility and listening to each individual Member who requests it;

• the Members, both internally and externally to the Association, recognize and undertake to make known to third parties the activity and strategic role of ASSYSTEW as a promoter of the aforementioned events, meetings and debates, as well as, more generally, as a supporter of the professional and personal growth of seafarers/, who work on yachts.

Ethical principles in the context of corporate governance

Social Bodies (Members' Assembly, Board of Directors, President).

The appointments of the members of the Social Bodies must take place through transparent procedures. The Social Bodies act and deliberate with full knowledge of the facts and of the facts, and in full autonomy, pursuing the objective of creating value for the Association and in compliance with the principles of legality, correctness and integrity.

The decisions of the members of the Social Bodies must be autonomous, that is, based on free assessment and pursuing the interests of the Association.

Independence of judgment is an essential requirement of the decisions of the Social Bodies, therefore the members must guarantee maximum transparency in the implementation and management of operations in which they have particular interests.

In particular, the members of the Board of Directors are individually required to carry out their role with seriousness and professionalism, thus allowing the Association to benefit from their specific skills.

Relations with Members

ASSYSTEW guarantees transparency and promotes information towards Members, in compliance with this Code and current regulations. The interests of all Members are promoted and protected, rejecting any particular or biased interest.

The Association supports a conscious and informed participation of Members in the life of the association. It also guarantees maximum confidentiality of sensitive and confidential information regarding Members. The Recipients involved must keep such information confidential and not abuse it.

The dissemination, to the outside, of information regarding relationships with Members occurs with prudence and caution. In any case, it is absolutely forbidden to spread false and tendentious news.

Transparency of the Association's accounting

The Association guarantees maximum transparency, accuracy, reliability and integrity of the information relating to its accounting: each operation and transaction must be correctly authorised and recorded, so as to be fully verifiable in its legitimacy, coherence and congruity, also with reference to the decision-making, authorisation and execution processes.

For each operation there must be adequate documentary support in order to be able to proceed, at any time, to carry out checks that certify the characteristics and motivations of the operation and identify who authorised, carried out, recorded and verified the operation itself.

Recipients who become aware of omissions, falsifications or negligence are required to report the facts to the Association's governing bodies.

3. Conduct Criteria

Relations between Associates and between Associates and the Association

Associates, natural persons, are required to respect and apply the General Ethical Principles both in their relationships with each other and in their relationships with ASSYSTEW. It is the obligation of Associates to do everything possible to actively participate in the life of the association, providing their contribution to the pursuit of the goals of ASSYSTEW.

Without prejudice to the respect of official and professional secrecy, each Associate is called upon to share their wealth of knowledge, skills and experience in matters of business ethics and association life.

Associates are required to respect the value and ownership of the information of which they become aware, as well as of the information of any nature and in any form that is collected and/or processed during the life of the association, and are also required not to disclose it without authorization, unless required by legal or ethical reasons.

To this purpose, they:

1. must use due caution in using the information acquired during the life of the association;

2. must not use the information contained either for personal advantage, or in ways that are contrary to the law or that are or may constitute harm to the purposes and values ​​of ASSYSTEW;

Relations with third parties and with the Institutions

Each Associate intends to establish with the other associates and in relations with the outside world a relationship inspired by correctness, transparency and efficiency, also by providing transparent messages and communications, avoiding interpretations of the information acquired, which have the sole purpose of discrediting third parties, activating incorrect dynamics.

Maximum confidentiality regarding the information is also guaranteed.

ASSYSTEW relates, at different levels, with entities and institutions in relation to the issues of interest to the association and in compliance with mutual roles and prerogatives: in institutional relations, it intends to act as a representative, authoritative, independent and autonomous interlocutor, with a view to contributing to the definition of development and growth policies in the sector. Each Associate or representative of the corporate bodies, in the context of relations with institutions and entities, is required to behave in an autonomous and independent manner, to provide correct information, as well as to make confidential use of the information of which he or she becomes aware by virtue of the mandate received, without obtaining undue advantages to the detriment of the Association and its members.

4. Methods of implementing the Code of Ethics

Internal control system

Each level of the organizational structure of the Association has the task of contributing to the creation of a mutual social control system, so that everyone complies with the code of ethics.

The Association aims to spread at all levels a culture characterized by awareness of the existence of controls and the adoption of a mentality oriented towards the exercise of control.

Sanctioning system

Any violation of the Code to the Board of Directors and the person indicated as responsible for the violation, where the report is considered reliable, is summoned by the Board of Directors to be heard and clarify his position; following its own assessment, and in the event of a confirmed violation, the consequent sanctioning measure is imposed.

In particular, proven violations of the Code by Associates are considered to be a cause of unworthiness of the same to retain - even temporarily, if not permanently, depending on the seriousness of the violation - the position of associate and determine their exclusion pursuant to art. 7.c of the Association's Statute, without prejudice to any liability actions ex lege.

Violations of the Code of Ethics committed by individuals who do not have the status of members such as professionals, collaborators, consultants and suppliers, previously ascertained with methods similar to those used with respect to members, determine a failure to fulfill the obligations arising from the employment relationship, with all contractual and legal consequences, also with reference to the relevance of the same as a disciplinary offense and may lead to: suspension and/or termination of the relationship, the prohibition to avail themselves in the future of the collaboration and/or professional services of the individual who has been found responsible.

Failure to comply with the provisions of the Code of Ethics by members of the corporate bodies may lead to the adoption, by the competent corporate bodies, of the most suitable measures provided for and permitted by law.

Entry into force, effectiveness, updating and amendments

The text of this Code of Ethics was adopted by resolution of the Board of Directors of the Association and becomes effective from the resolution of approval of the Assembly; the text in force is – at least annually – subject to verification and possible updating by the Board of Directors.

Every update, modification and integration must also be approved by the Members' Assembly.

A copy of the Code is made available for consultation on the website (in electronic format) as well as at all the Association's offices (in paper format).