ETHICS CODE AND BUSINESS CONDUCT
HONESTY, INTEGRITY, AND CORRECTNESS AT THE BASE OF OUR DAILY COMMITMENT
Honesty, integrity and fairness are the key factors that have always accompanied IBIS since its foundation by helping it grow to become a solid reality in the world of radiology.

The fundamental principles we have been inspired by are the constant respect for human values and the achievement of a consistent corporate reputation referring to two fundamental codes of conduct:

The Code of Ethics, where are expressed the commitments and ethical responsibilities of IBIS in the activity carried out forward to customers and within the company’s internal activities, with regard to its suppliers, employees and collaborators.

The Code of Business Conduct, which IBIS undertakes to respect and in which the minimum and non-negotiable standards of corporate behavior are set.

CODE OF ETHICS  & CONDUCT 

  

The hereby code of ethics has been approved by the administration of IBIS S.R.L

 

Summary

 

PURPOSE AND RECIPIENTS

1.1     Legality

1.2     Correctness

1.3     Non discrimination

1.4     Confidentiality

1.5     Diligence

1.6     Loyalty

2        RELATIONSHIP WITH EMPLOYEES AND COLLABORATORS

2.1     Recruitment

2.2     HR Management

3        WORKPLACE

3.1     Working Environment

3.2     Safety of the workplace

4        COMPANY MANAGEMENT

4.1     Compliance with internal procedures

4.2     Accountant management

4.3     Assets protection

4.4     Communication

5        EXTERNAL RELATIONS

5.1     Relations with the Authorities and Public Administration

5.2     Relations with political and Trade union Organization

5.3     Relations with Customers and Suppliers

6        INTERNAL CONTROL SYSTEM

7        GUIDELINES OF THE SANCTIONATORY SYSTEM

 

 

 

INTRODUCTION

IBIS is a company founded in 2002 following several successive company demergers; it can be said that the spirit and governance of the Company has lasted for several decades during which it has acquired considerable mastery and experience. IBIS has always operated in the medical sector producing mobile or stationary radiology equipment for hospitals or clinics. Over the years the range of equipment has been implemented with the inclusion of units for veterinary radiology, a sector in which the company immediately distinguished itself for the reliability and the constructive quality of its products. The production of C-Arms for fluoroscopy completes the macro range of products that IBIS is able to make available to end customers and distributors. Operations are worldwide at distribution channels with a geographical coverage of about 85% of the world’s territory.

The compilation of a code of conduct and ethics is the result of several months of study and comparison with other companies and has become necessary, not so much for obligations imposed by institutions but as a need to externalize what are the foundations and principles that the Company considers binding and therefore adopts and follows during any commercial transaction, choice or decision.

IBIS is aware that the authority of a company is recognized, in addition to the expertise of its employees and the high quality of the service provided to customers, also from the attention given to the needs of its customers and from relationships with suppliers as well as with the collaborators.

The principles that have always inspired the work of IBIS are formally collected in this Code of Conduct in the belief that reliability, trust, quality and esteem are built every day by respecting the rules and valuing people.

This Code of Ethics represents, therefore, a distinctive and identifying element towards the market and third parties, whose knowledge and sharing, required to all those who work in the Company or who collaborate with it, constitute the foundation of our activity and the first step to compete for the pursuit of our vision.

IBIS’ goal is therefore to pursue excellence in the market in which it operates, safeguarding the environment and the safety of the people involved through the consistency of a respectful behavior of Social Ethics, obtaining satisfaction and ensuring added value for the Employee, for the Customer and, in general, for all the figures that contribute to the operation of the Company.

 

PURPOSE AND RECIPIENTS

This Code of Ethics (hereinafter, the “Code”) illustrates the set of ethical and moral principles that underlie IBIS’s activities (hereinafter, “Company” or “IBIS”) as well as the lines of behavior adopted by Company both within its own business (in relations with employees) and outside (in relations with institutions, suppliers, customers, business partners) (hereinafter, “Stakeholders”).

Respect of these principles is of fundamental importance for achieving the Company’s corporate mission and for guaranteeing, maintaining and implementing its reputation in the socio-economic context in which it operates.

First of all, IBIS firmly believes that every activity must be carried out ethically, recognizing itself in the principle established by art. 41 of the Italian Constitution, according to which “the private economic initiative cannot be carried out in contrast with the social utility or in such a way as to damage the security, freedom and human dignity“.

This Code is binding on IBIS directors and employees, as well as for all those who work and collaborate, on a permanent or fixed-term basis, on behalf of the Company (hereinafter referred to as the “Recipients”).

The Code will be widely spread within the internal governance structure, and wide communication to the outside, also through its website.

IBIS also undertakes to adopt any further provision so that the principles and provisions of the Code can be duly disclosed and applied.

GENERAL PRINCIPLES

The conduct of the Recipients, at all company levels, is based on the principles of legality, correctness, non-discrimination, confidentiality, diligence, and loyalty.

1.1      Legality

IBIS operates in full compliance with the law and with this Code.

All Recipients are therefore required to comply with all applicable regulations and to constantly update on legislative developments.

1.2      Correctness

Correctness and moral integrity are an indefectible duty for all Recipients.

The Recipients are required not to establish any special relationship with third parties, which is the result of external solicitations aimed at obtaining improper advantages.

In carrying out their activities, the Recipients are obliged not to accept donations, favors or utilities of any kind (except objects of low value for the exclusive purpose of personal gratitude or on the occasion of national and religious holidays) and, in general, not to accept any counterparty in order to give advantages to third parties in an improper manner.

In turn, the Recipients must not make donations in cash or goods to third parties or otherwise offer illicit benefits or favors of any kind (except for objects of modest value or gifts of commercial courtesy authorized by the Company) in connection with the activity they lent for the benefit of IBIS. The intrinsic conviction of acting in the interests of the Company does not exonerate the Recipients from the obligation to comply promptly with the rules and principles of this Code.

1.3      Non discrimination

In relationships with the stakeholders and in particular in the selection and management of personnel, in the work organization, in the choice and management of suppliers, as well as in relations with the Institutions and Institutions, IBIS avoids and rejects any discrimination concerning the age, sex, race, sexual orientation, state of health, political and trade union opinions, religion, culture and nationality of its interlocutors.

1.4      Confidentiality

IBIS undertakes to ensure the protection and confidentiality of the personal data of Recipients and Stakeholders, in compliance with any applicable European or national law regarding the protection of personal data.

Recipients are required not to use confidential information, learned by reason of their work, for purposes unrelated to the exercise of such activity, and in any case to act always in compliance with the confidentiality obligations assumed by IBIS towards all stakeholders.

In particular, the Recipients are bound by strict confidentiality on documents suitable for disclosing know-how, technical information, commercial information and corporate transactions.

1.5      Diligence

The relationship between IBIS and its employees is based on mutual trust: employees are therefore required to work to promote the interests of the company, in compliance with the values set out in this Code of Ethics.

The Recipients must refrain from any activity that could constitute a conflict with the interests of IBIS, renouncing the pursuit of personal interests in conflict with the legitimate interests of the Company.

In cases in which the possibility of existence of a conflict of interests can be represented, the Recipients are required to contact, without delay, their hierarchical superior so that the company can evaluate, and possibly authorize, the potentially conflicting activity.

In cases of violation, the Company will take all appropriate measures to stop the conflict of interest, reserving the right to act for its protection.

1.6      Loyalty

IBIS and the Recipients are committed to achieving fair competition, in compliance with national and EU legislation, in the knowledge that virtuous competition is a healthy incentive for innovation and development processes.

 

2       RELATIONSHIP WITH EMPLOYEES AND COLLABORATORS

2.1      Recruitment

The evaluation and selection of personnel are carried out according to correctness and transparency, respecting equal opportunities in order to combine the needs of IBIS, with the professional profiles, ambitions and expectations of the candidates.

IBIS undertakes to apply all measures necessary to avoid any form of favoritism in the selection process of personnel using objective and meritocratic criteria, respecting the dignity of the candidates and in the interest of the good performance of the company.

The personnel hired, also through the implementation of this Code, receive clear and correct information about the roles, responsibilities, rights and duties of the parties.

2.2      HR Management

IBIS protects and enhances its human resources, committing itself to maintaining constant the conditions necessary for professional growth, knowledge and skills of each person, making the appropriate training for professional updating and any initiative aimed at pursuing this purpose.

IBIS promotes the participation of workers in the life of the company, providing participatory tools able to gather the opinion and suggestions of workers, ensuring their broader participation.

The Company is firmly committed to counteracting episodes of mobbing, stalking, psychological violence and any discriminatory behavior damaging the dignity of the person inside and outside the company premises.

Relations between employees must take place with loyalty, fairness and mutual respect, in compliance with the values of civil coexistence and the freedom of people.

3       WORKPLACE

3.1      Working Environment

IBIS is committed to offering its staff a healthy, safe and respectful working environment for workers’ dignity.

3.2      Safety of the workplace

Safety in the workplace is ensured both by strictly implementing the provisions of the law in force and by actively promoting the culture of safety through specific training programs. Staff training is a central element of the management system adopted.

IBIS protects the health of its workers, also ensuring compliance with hygiene and health prevention regulations.

4       COMPANY MANAGEMENT

4.1      Compliance with internal procedures

IBIS believes that management efficiency and the culture of control are essential elements for achieving the objectives. The Recipients are required to strictly comply with the procedures and instructions inside the company.

Recipients must act on their respective authorization profiles and must retain all appropriate documentation to track actions taken on behalf of the company

4.2      Accountant management

In the accounting management activity, the Recipients are called to act in compliance with the principles of truthfulness, accuracy and transparency, in order to protect the reputation of IBIS both internally and externally.

Compliance with these principles also allows the company to plan its operating strategies based on its real economic and financial situation.

All items reported in the accounts must therefore be supported by complete, clear and valid documentation, avoiding any form of omission, falsification and / or irregularity.

In the case of assets or economic elements based on valuations and estimates, the related registration must be based on criteria of reasonableness and prudence.

4.3      Assets protection

Recipients exercise their functions trying to rationalize and contain the use of company resources.

Recipients are required to correctly apply the security provisions to protect hardware devices from unauthorized access, which could seriously damage the personal data protection rights of IBIS staff and customers.

4.4      Communication

IBIS provides to make available to stakeholders suitable communication tools through which they can interact with the company to forward requests, ask for clarifications or make complaints.

IBIS promotes an effective corporate communication able to put the company in touch with civil society, in order to incorporate the needs of the community and to spread its values and its mission.

The information disseminated to the stakeholders is complete and accurate so that the recipients are allowed to make correct and informed decisions.

The advertising promotion of IBIS, where and when expected, respects ethical values, protecting minors and repudiating vulgar, offensive or harmful messages against minorities or social classes.

 

5       EXTERNAL RELATIONS

5.1      Relations with the Authorities and Public Administration

 

Relations with the Authorities and with the Public Administration must be based on the utmost clarity, transparency and collaboration, in full compliance with the law and according to the highest moral and professional standards.

The recipients, unless expressly authorized, cannot relate in the name and on behalf of IBIS with the Authorities and with the Public Administration.

In relations with the Public Officials, with the Public Service Officers, and with the Public Administration in general, the Authorized Recipients will behave with the highest levels of correctness and integrity, refraining from any form of pressure, explicit or veiled, aimed at obtaining any advantage undue for themselves or IBIS.

In this regard, the Authorized Recipients will be required to strictly comply with the provisions of this Code, as well as, more generally, with the directives given by the management of IBIS.

5.2      Relations with political and Trade union Organization

 

IBIS does not favor or discriminate against any political or trade union organization.

The Company abstains from providing any undue contribution in any form to political parties, trade unions or other social groups, except for specific exceptions and in any case always within the limits of what is permitted by current regulations.

The Recipients are required to refrain from any direct, indirect or pointed out pressure against politicians or trade union representatives.

5.3      Relations with Customers and Suppliers

Recipients relate with third parties with courtesy, competence and professionalism, in the belief that the protection of the image and reputation of the company depends on their conduct and consequently the achievement of corporate objectives.

In particular, Recipients must refrain from any form of unfair or deceptive behavior that may induce customers or suppliers to rely on unfounded facts or circumstances.

The Recipients are obliged to commit themselves constantly to provide timely and high-quality services to customers, trying to limit any form of disruption or delay in order to maximize customer satisfaction.

Relations with suppliers are based on loyalty, correctness and transparency.

The choice of suppliers is made on the basis of objective criteria of economy, opportunity and efficiency.

The choice of suppliers on purely subjective and personal grounds or, in any case, by virtue of interests conflicting with those of companies, is precluded.

The Recipients must carry out every possible check so that even suppliers and customers are able to comply with the fundamental ethical principles set forth in this Code..

 

6       INTERNAL CONTROL SYSTEM

Compliance with the provisions of this Code is entrusted to the prudent, reasonable and careful supervision of each of the Recipients, within their respective roles and functions within the company.

All Recipients are invited to report to their immediate superiors facts and circumstances potentially in contrast with the principles and provisions of this Code.

The management of IBIS takes every necessary measure to stop the violations, being able to resort to any disciplinary measure in compliance with the law and the rights of workers, including trade union rights.

7       GUIDELINES OF THE SANCTIONATORY SYSTEM

The internal control system is oriented towards the adoption of tools and methodologies aimed at combating potential business risks, in order to ensure compliance not only with laws, but also with internal provisions and procedures.

In fact, the violation of the principles established in the Code and in the procedures indicated in the internal controls compromises the fiduciary relationship between the Company and its administrators, employees, consultants, collaborators in various capacities, customers, suppliers, commercial and financial partners.

Such violations will therefore be immediately prosecuted by IBIS in an incisive and timely manner, through the adoption of adequate and proportionate disciplinary measures.

The effects of violations of the Code of Ethics and internal protocols must be taken into consideration by all those who, in any capacity, maintain relations with IBIS. Depending on the seriousness of the conduct committed by the person involved in one of the illegal activities required by the Code, IBIS will promptly take the appropriate measures, regardless of the possible exercise of the prosecution by the judicial authority.

Without prejudice to the foregoing, behaviors in violation of the Code of Ethics constitute:

  • serious non-performance for employees (workers, employees, middle managers and managers), with sanctions, applied according to severity, provided for by the national collective labor agreement (verbal reprimand, written reprimand, suspension from work and pay, dismissal for just cause or Justified reason); in the case of a pending trial or execution of a restrictive measure of personal freedom assumed towards the employee, before adopting the disciplinary measure, the sanction of the suspension from the service and the remuneration may be adopted, for the duration corresponding to the outcome of the prosecution or until the end of the duration of the restrictive measure of personal liberty;
  • cause of immediate termination of the relationship for external and Para subordinate collaborators;
  • cause of immediate termination of the relationship for suppliers, contractors and subcontractors.

 

The identification and application of sanctions will always take into account the general principles of proportionality and adequacy with respect to the alleged violation.

In all the aforesaid hypotheses, IBIS also reserves the right to exercise all the actions it deems appropriate for the compensation of the damage suffered as a consequence of the behavior in violation of the Code of Ethics

 

This Code of Ethics has been approved by the Administration of IBIS S.R.L.

IBIS S.r.l.