Code of Ethics

This Code of Ethics defines the fundamental principles and values ​​that guide the conduct of Strategies Srl, its employees, collaborators, partners, and all those who interact with the company. Strategies Srl's primary mission is to train and develop the skills of its people, offering high-quality educational services that prepare the next generation to meet the challenges of the world of work. The goal is to promote transparency, integrity, and accountability in all its activities, respecting individual rights and applicable regulations.

1. General Principles

Training and Skills Development:
Strategies Srl is passionately dedicated to training people, believing that education and continuous improvement are essential for personal and professional growth. The company designs and offers innovative training programs aimed at developing technical and transversal skills, promoting learning as a driver of progress for society and organizations.

Valorization of New Generations and Women:
Strategies Srl is a company that firmly believes in the value of young people, new generations, and female talent. Currently, 75% of its employees are women, and 87% are under 40. The company is committed to fostering an inclusive work environment where diversity is celebrated and innovative ideas are valued. Strategies Srl offers growth and training opportunities for young professionals, supporting mentorship and skills development programs, and promotes policies that foster female leadership, recognizing the essential contribution of women to business development and innovation.

Respect for Human Rights:
Strategies Srl is committed to respecting fundamental human rights, in accordance with the principles enshrined in the Universal Declaration of Human Rights. The company guarantees equal opportunities for all, regardless of gender, ethnicity, religion, sexual orientation, age, or disability. We firmly condemn any form of discrimination, abuse, or violation of rights, and are committed to promoting fair and equitable labor practices. Strategies Srl adopts policies that support a work environment that safeguards the dignity, health, and well-being of employees, and offers secure mechanisms for reporting any inappropriate behavior.

Integrity and Honesty:
All members of Strategies Srl are required to operate with transparency, honesty, and fairness in every situation, both towards customers and towards colleagues, partners, and suppliers.

Legality:
The company and all its collaborators strictly comply with the laws and regulations in force in the countries in which they operate, actively collaborating with the Public Administration and the competent authorities, where required.

Transparency:
Information regarding company activities, services offered, and internal processes is managed transparently, ensuring clarity and completeness for customers and stakeholders. Every transaction must be clearly and traceably recorded, allowing for appropriate audits and controls to ensure its legitimacy.

Ethical Responsibility in the Use of Technology:
Strategies Srl recognizes the importance of ethics in the management and use of technologies, including artificial intelligence (AI). The company is committed to using digital tools responsibly, ensuring that AI applications are developed and implemented in compliance with ethical principles, such as algorithmic transparency, non-discrimination, and personal data protection. The technologies used must always respect human dignity and promote the well-being of the community.

Social and Environmental Responsibility:
Strategies Srl actively promotes social initiatives and is committed to respecting the environment, adopting sustainable practices and encouraging responsible behavior towards communities and the ecosystem. The company has long supported UNICEF, supporting projects that benefit children and promote education in disadvantaged areas of the world. This commitment is expressed through donations and active participation in campaigns to improve children's living conditions, ensure their access to education, and promote equal opportunities for growth and development. In terms of environmental issues, Strategies Srl adopts measures to reduce the environmental impact of its operations, such as the use of sustainable materials, waste recycling, and optimizing energy consumption. The company is also committed to raising awareness among its employees and stakeholders about environmentally responsible practices, contributing to environmental protection for future generations.

2. Conduct towards Customers and Participants

Quality of Service:
The company is committed to providing high-quality training services, professionally responding to client needs and ensuring a safe and respectful training environment. Strategies Srl works to meet the individual needs of participants, customizing training services where possible to ensure that the learning experience is meaningful and tailored to each client's specific expectations.

Respect, Fairness and Courtesy:
Every interaction with participants must be characterized by respect, courtesy, and availability. The company is committed to treating all participants fairly and impartially, ensuring that everyone receives the same level of service and support, regardless of their background or individual needs. Participants' diversity and opinions are welcomed and valued, creating an inclusive and collaborative environment. To this end, all Strategies Srl employees are trained and educated on the culture and principles of customer satisfaction, which have guided our relationship with our clients since the company's founding in 1997. This unwavering commitment to excellence in customer service ensures that every interaction contributes to a positive and satisfying experience for participants.

Privacy and Confidentiality:
Strategies Srl protects the confidentiality of clients' and participants' personal data in accordance with current data protection regulations (GDPR). The company adopts stringent data management policies, using secure tools for data collection and storage. Personal data is stored on servers located in the European Union, and the company employs advanced cybersecurity to protect all sensitive information. This protection system includes the use of continuously updated hardware and software to prevent any risk of breach and ensure data security.

3. Conduct towards Employees and Collaborators

Human Resources Development:
The company recognizes the importance of its people as a strategic resource and promotes an inclusive, equitable, and safe work environment. Continuous training and skills development are encouraged to ensure professional growth. Strategies Srl invests in the well-being of its employees, offering development and support programs to achieve their personal and professional growth ambitions. The company provides career advancement and mentorship opportunities to help each employee reach their potential.

Psychological Well-being and Work-Life Balance:
Strategies Srl is committed to supporting the psychological well-being of its employees, offering access to professional psychological support and promoting workplace peace of mind initiatives to prevent stress. The company recognizes the importance of a work environment that fosters mental health and overall well-being, helping employees feel valued and supported.

Non-Discrimination:
Strategies Srl is committed to ensuring equal opportunities, avoiding any form of discrimination based on gender, ethnicity, religion, sexual orientation, age, disability, or any other personal characteristic. The company strives to foster a culture of respect and inclusion, where differences are valued as a strength.

Zero Tolerance for Harassment and Bullying:
Strategies Srl adopts a zero-tolerance policy towards any form of harassment, bullying, or inappropriate behavior. Employees have clear procedures for reporting such incidents, with the assurance that reports will be treated with the utmost confidentiality and seriousness. The company takes prompt and appropriate action to address and resolve each reported incident, ensuring a safe and respectful work environment for all.

Health and Safety:
The company takes all necessary measures to ensure workplace safety and the physical well-being of its employees, in collaboration with DA.TA. Srl, which is responsible for corporate safety management. Special attention is paid to accident prevention and employee protection through safety training and compliance with applicable regulations.

4. Conduct towards Suppliers and Partners

Fairness and Transparency:
Relationships with suppliers and partners are managed with integrity, transparency, and in full compliance with agreed-upon conditions. Strategies Srl selects its partners based on objective criteria, evaluating not only the quality and reliability of the services or products offered, but also their commitment to environmental sustainability and social responsibility. The company favors collaborations with suppliers who adopt sustainable practices and share similar ethical values.

Loyalty:
Strategies Srl aims to build lasting relationships with its suppliers, based on trust and mutual collaboration. The company guarantees to honor its commitments, fostering a stable and mutually beneficial relationship.

Conflict of Interest Management:
The company adopts a rigorous approach to preventing and managing any conflicts of interest that could compromise the integrity of supplier relationships. Any situation that could give rise to a conflict is promptly reported and addressed transparently. Strategies Srl has clear procedures for resolving these cases fairly, ensuring that decisions are always made in the company's best interests and in compliance with ethical principles.

Transparency in Payments:
Strategies Srl is committed to respecting the payment terms agreed with suppliers, ensuring maximum transparency in the management of financial transactions. This commitment strengthens trust and integrity in relationships with partners, demonstrating the company's seriousness and reliability.

5. Information Management and Confidentiality

Information Protection:
All company information, including that relating to projects, strategic plans, and sensitive data, must be treated with the utmost confidentiality. Access to this information is limited to authorized personnel, who are required to comply with company data protection regulations. Information relating to our faculty is particularly protected: on the company website, access to this section is password-protected, ensuring that only authorized individuals can view faculty details, preventing misuse or unauthorized contact attempts by third parties.

Cyber ​​Security:
The company takes appropriate measures to protect its IT systems and digital information from unauthorized access, in collaboration with Evolumia Srl and KNE Srl. Strategies Srl is committed to using updated software and advanced technologies to prevent security breaches. IT systems are constantly monitored and updated to ensure protection against cyber threats.

Regular Cyber ​​Security Training:
To ensure all employees understand and comply with data protection measures, the company organizes periodic cybersecurity training sessions. These courses educate staff on information management best practices and the secure use of digital systems, helping to minimize the risks associated with handling sensitive data.

Sensitive Information Management Policies:
Strategies Srl implements strict policies for managing sensitive information, including protocols that limit access to critical data to authorized personnel only. Furthermore, the company has established procedures for the secure destruction of obsolete or no longer needed information to prevent potential data leaks.

Accessibility of Graduate Registers:
The registers of certified graduates in various disciplines are accessible to the public, but only in a controlled manner. To consult the certificates, you need to know the specific name of the person: only then does the platform provide information on the certificate held by the graduate, thus ensuring a level of privacy for certificate holders.

6. Social Responsibility and Ethical Commitment

Support for Social Initiatives:
Strategies Srl actively participates in social projects and charitable initiatives, promoting the well-being of the communities in which it operates. The company has long collaborated with UNICEF, supporting programs to improve living conditions and access to education for children in disadvantaged areas of the world. Furthermore, Strategies Srl contributes to local educational projects that promote social inclusion and organizes volunteer activities in which employees are encouraged to participate, such as fundraising campaigns or support days for non-profit organizations.

Commitment to Environmental Sustainability:
The company is committed to reducing the environmental impact of its operations by adopting sustainable practices such as recycling materials, using eco-friendly products, and implementing energy efficiency measures in its offices. Strategies Srl constantly works to raise awareness among its staff and stakeholders about the importance of environmental sustainability and encourages responsible behavior in protecting the environment.

Adherence to International Ethical Standards:
Strategies Srl adheres to internationally recognized ethical principles, including the United Nations Global Compact, committing to respect the ten fundamental principles regarding human rights, labor, the environment, and the fight against corruption. This commitment reflects the company's desire to operate with integrity and responsibility, promoting sustainable and socially responsible business practices.

Code of Conduct for Staff:
Every member of the company is responsible for acting ethically and in compliance with this Code. Strategies Srl has established secure channels for reporting non-compliant behavior or violations, which can be communicated to Management or the Quality Manager. The company guarantees that all reports will be treated with the utmost seriousness and confidentiality, and that the necessary measures will be taken to resolve any ethical concerns.

7. Implementation and Monitoring

Management is committed to promoting awareness and application of this Code of Ethics among all employees.

Periodic monitoring of compliance with the principles set forth is carried out through a review of corporate practices and ongoing reflection on the organization's ethical activities.

This process allows you to verify adherence to established values ​​and norms and to identify opportunities to improve company policies and behaviors, adopting corrective measures when necessary.

In the event of violations of the Code of Ethics, the company takes appropriate disciplinary measures, which may include formal warnings, suspensions, or, in the most serious cases, termination of employment.

Each case is addressed seriously and transparently, ensuring that actions are proportionate to the seriousness of the violation.

To facilitate reporting of unethical or inappropriate behavior, Strategies Srl adopts whistleblowing principles, encouraging its employees and other interested parties to report any violations or concerns related to corporate ethics, even anonymously. The company is committed to protecting whistleblowers, ensuring that reports are handled with the utmost confidentiality and without any form of retaliation.

Management is committed to responding promptly to reports and taking all necessary actions to ensure an ethical working environment that complies with company values.

Approved by Management on September 09, 2024