Pursuant to the Organisational, Management and Control Model established by Italian Legislative Decree no. 231 of 8 June 2001, the CEUR Foundation has decided to adopt a Code of Ethics.

1. INTRODUCTION

1.1 The CEUR mission

The CEUR Foundation – European Centre for University and Research – has been operating since 1990 inspired by the horizontal sense of subsidiarity, i.e. in the spirit that the citizen, both as an individual and through intermediate bodies, must have the possibility to cooperate with the institutions in defining the actions that affect the social realities closest to him.
CEUR therefore carries out its activities in the field of education and training through various actions: the establishment and management of colleges and university residences; the promotion of cultural and educational activities and research among young scholars and teachers and the management of guidance services.
CEUR’s educational programme is focused on the person, i.e. the wishes and expectations of the students, true protagonists of the university environment and the working world.

1.2 Establishing the ethics of activity

It is the CEUR Foundation’s conviction that the management of its activities, which are of significant public interest – and in particular the management of funds or contributions of public origin – should be based on ethical values, helping to convey an image of reliability, propriety and transparency of activities carried out in pursuit of its objectives.
The activity of the Foundation and especially its mission require that relations with the outside world be based on a strict observance of the laws, the market rules and the inspiring principles of fair competition, respecting the legitimate interests of its stakeholders.
It is therefore necessary to identify and define those valuesthat all stakeholders of the Code of Ethics – directors, auditors, employees, internal or external contractors at any level and without exception, customers, suppliers and all those who directly or indirectly permanently or temporarily establish relationships or relations with the Foundation, operating for the pursuit of its objectives – must share, accepting responsibilities, roles and models of conduct of action in the name and/or on behalf of the Foundation itself.

1.3 Issuance of the Code of Ethics

The issuance of the Code of Ethics is one of the tools put in place by the Foundation in order to guarantee the dissemination and compliance with principles, rules and general standards of behaviour aimed at safeguarding ethical values.
The Code of Ethics is one of the indispensable elements of the management organisational model that the Foundation has decided to adopt, following the enactment of Italian Legislative Decree no. 231/2001 and subsequent amendments and additions. For this same reason, a Supervisory Body will also be established.
The Code of Ethics of the CEUR Foundation therefore contains provisions aimed specifically at preventing the commission of the crimes covered by the aforementioned decree. The directors, auditors, employees and collaborators at any level of the Foundation must therefore refrain from engaging in, contributing or giving cause to the conduct of behaviours that, although they do not constitute in themselves the types of offences included among those previously noted, may facilitate them.

1.4 Unethical behaviour and the value of reputation

The conduct of anyone – individual or organisation – on behalf of the CEUR Foundation that violates the rules of civil coexistence and proper social and commercial relations is not ethical. With regard to the management of activities, unethical behaviour compromises the relationship of trust and can foster hostile attitudes towards the Foundation.
A good reputation fosters relationships with the institutional, commercial, entrepreneurial and financial interlocutors, attracts the best human resources and conveys reliability to creditors and serenity of relationships with suppliers and third parties.

1.5 Stakeholders

Stakeholders are those parties – individuals, groups, organisations, institutions – who contribute to the realisation of the CEUR Foundation’s mission, or which in any case have an interest in its accomplishment.
In a general sense, all those whose interests are influenced by the direct or indirect effects of the CEUR Foundation’s activities are considered stakeholders. These also include national, international and European community associations and institutions.
The maintenance and development of relationships of trust and mutual cooperation with the stakeholders is therefore a primary interest of the Foundation, also for the purpose of the mutual satisfaction of the parties involved.

1.6 Structure of the Code of Ethics

The Code of Ethics consists of:

1. The introduction, which frames the mission of the CEUR Foundation and the value it attributes to an ethical approach to its activity.
2. The general principles, which define the ethical values.
3. Guidelines, rules and general standards of conduct.
4. The Supervisory Body as per Italian Legislative Decree no. 231/2001.

1.7 Scope of application

Recipients of the Code of Ethics are all collaborators, without any exception, and all those who directly or indirectly permanently or temporarily establish relationships with the CEUR Foundation and work to achieve its objectives.
The CEUR Foundation is committed to the dissemination, verification and monitoring of this Code of Ethics.
In any commercial relationship, all counterparties must be informed of the existence and contents of the provisions of this Code of Ethics and are required to comply with them.

2. ETHICAL PRINCIPLES

2.1 Equal opportunities, honesty and compliance with the rules

The guarantee of the principle of honesty and equal opportunities for access to the activities and services provided by the CEUR Foundation represent the basic ethical principles for all activities carried out by the Foundation for the accomplishment of its mission.
As part of their professional activities, collaborators, suppliers and all persons working in the name and on behalf of the CEUR Foundation are required to comply with current national and EU laws, and, where applicable, the professional ethical standards. In no case is conduct that violates these rules justified or tolerated by the Foundation, even if it was carried out in the interest of the Foundation itself.

2.2 Non-discrimination

In decisions affecting relations with its interlocutors, the CEUR Foundation does not allow any kind of discrimination based on age, gender, sexual preference, health, race, nationality, political opinions or religious beliefs of its interlocutors.

2.3 Prevention of corruption

In the performance of its activities, the CEUR Foundation forbids any action involving or by third parties capable of undermining impartiality and independence of judgement.
To this end, it implements the measures necessary to prevent and avoid corruption and other conduct that may increase the danger of committing the offences envisaged by Italian Legislative Decree no. 231/01.
In this regard, the CEUR Foundation does not allow paying or accepting sums of money, gifts or favours to/from third parties for the purpose of providing direct or indirect benefits to the Foundation itself. However, it is allowed to accept or offer gifts that fall within the usual customs of hospitality, courtesy and special occasions.

2.4 Health, safety and value of human resources

Respect for the physical and cultural integrity of the person is a basic ethical value of the CEUR Foundation.
Employees of any level are an indispensable resource for the success of the Foundation’s mission.
The CEUR Foundation protects and promotes the value of human resources, with the aim of improving and increasing the experience and wealth of skills possessed by each employee and collaborator; it guarantees working conditions that respect individual dignity and safe and healthy work environments.
The CEUR Foundation supports and respects human rights, in accordance with the UN Universal Declaration of Human Rights.

2.5 Propriety in relations with employees and collaborators

In the application of hierarchical rules in relations with employees and collaborators, the CEUR Foundation guarantees that no occasions arise in which the exercise of authority is detrimental to the dignity, professionalism and autonomy of the worker.
The CEUR Foundation makes its own organisational choices while safeguarding the professional value of its employees and collaborators.

2.6 Conflicts of interest

The CEUR Foundation commits to put in place appropriate measures to avoid parties involved in transactions having conflicts of interest.
A conflict of interest is considered to exist both when an employee or contractor pursues interests other than those of the company mission or personally benefits from the organisation’s business opportunities, and when representatives of the stakeholders (working together in groups, associations, public or private institutions) act in a manner contrary to the fiduciary duties of their position.

2.7 Foundation assets and interests of third parties

The protection of the integrity of the Foundation’s assets, of the interests of creditors and in general of third parties is a component of the basic ethical tradition of the CEUR Foundation.

3. GUIDELINES, RULES AND GENERAL STANDARDS OF CONDUCT

3.1 Shareholders and corporate governance

3.1.1 Relations with Shareholders

The CEUR Foundation works to ensure that the participation of shareholders in the decisions within their remit is widespread and informed and that everyone is given equal information.

3.1.2 The corporate bodies

The activities of the Corporate Bodies are carried out in full compliance with the rules established by the By-Laws and current national and European Community legislation.

3.1.3 Governing bodies – The duties of individuals

Parties elected or appointed to governing functions are required to:

• be actively engaged so that the Foundation can benefit from their specific skills;
• continuously participate in the work of Boards and Committees, Board of Directors and shareholders’ meetings, promptly reporting any situation of conflict of interest involving them;
• maintain the confidentiality of any information acquired in the performance of one’s mandate;
• always place the interests of the corporate mission ahead of any particular interest of the individual.

3.2 Transparency, completeness and confidentiality of information

The CEUR Foundation is committed to managing the flow of information to stakeholders so that the information meets the requirements of truthfulness, completeness and accuracy, including financial, accounting or management data.
The CEUR Foundation also ensures the confidentiality of the information in its possession, defining and continuously updating the specific procedures and security measures required by law for the processing of personal, common and sensitive data.
All those who in the exercise of their work functions have access to confidential information and data are required to use such data only for the purposes permitted by law.

3.3. System implementation

The creation of an effective internal system for the purposes of Italian Legislative Decree no. 231/01 is entrusted to the entire organisational structure in order to involve all workers in aspects within their remit.
All are required to strictly comply with company procedures within their respective responsibilities and functions.

3.4. Employees and non-employees 

3.4.1. Recruiting

The assessment of the personnel to be hired is carried out based on the correspondence of the candidates’ profiles with the company’s needs, safeguarding the equal opportunities of all parties involved.
The questions and information asked or requested of the applicants during the recruiting process are strictly connected to the verification of the aspects envisaged by the professional and psycho-aptitude profile, respecting the private sphere and the opinions of the applicant.

3.4.2. Establishments of the employment relationship

The personnel is hired with a formal employment contract in the manner prescribed by the law and by current collective bargaining.
To establish an employment relationship the employee must sign the pertinent contract, as well as the commitment to comply with the provisions of the Code of Ethics. The person is also fully informed about:

• the characteristics of the job and the tasks to be performed,
• the regulatory and contributory elements of the contract,
• the regulations and procedures in use at the Foundation for the prevention of possible health risks deriving from work.

3.4.3. Personnel management

With regard to the management of personnel, the CEUR Foundation forbids any form of discrimination.
With respect to personnel management processes, the decisions made are based on the correspondence between the needs of the Foundation and the profiles of the workers as well as on considerations of merit. The same applies to access to different roles or tasks.

3.4.4. Use of company assets

Personnel must conduct themselves in a manner that is responsible and respectful of the operating procedures established for the use of company assets, where required documenting their use.

3.4.5. Health and safety

The CEUR Foundation is committed to preserving the health and safety of workers, primarily with preventive measures. To this end, it works to promote and spread the culture of safety at work.
Collaborators commit to respect the standards and obligations deriving from applicable health and safety regulations and from this code.

3.5. Community

3.5.1 Responsibility towards the community

The CEUR Foundation is aware of its prevailing social nature and the effect that activities carried out for the accomplishment of its mission can have on the economic and socio-cultural development of the context of reference.
For this reason, it conducts its activities in full respect of local and national institutions, associations, communities, etc. in order to acquire an excellent reputation that contributes to legitimising its work in the community.

3.5.2. Respect for the environment

The CEUR Foundation commits itself to carrying out its activities in a manner that contributes constructively to the protection of the environment.

3.5.3. Suppliers and service providers

The CEUR Foundation requires its suppliers and service providers in general to respect the ethical principles contained in this document.
In choosing its suppliers, besides financial convenience, the CEUR Foundation also considers the technical/financial capacity of its contractors, assessing their overall reliability with respect to the specific elements of the services to be rendered.
Relations with suppliers and service providers (within the limits established by internal procedures) are always governed by specific contracts aimed at establishing the maximum clarity of the relationship.

3.5.4 Public administration

Relations with public administrations and public institutions are the sole responsibility of the corporate functions assigned and authorised for this purpose. The employees, contractors or representatives of the CEUR Foundation must not promise, request, offer or receive gifts or favours to/from public officials, public service employees or employees in general of the public administration or other public institutions, Italian and foreign.
Therefore, in relations with public officials and/or in charge of public service, no form of gift or free benefit may be promised, requested, offered or received that can be interpreted as exceeding the normal level of courtesy or in any case aimed at acquiring favourable treatment in conducting any operation attributable to the activity of the foundation.
For special occasions (e.g. Christmas holidays), according to local uses and customs the CEUR Foundation may offer some interlocutors, including representatives of the public administration, goods of modest value or publications published or edited by the Foundation.
In order to not carry out acts in conflict with the law or in any case prejudicial to the image and integrity of the Foundation, such operations and the related management of financial resources must be carried out only by specifically authorised departments in respect of pertinent laws and the principles of the Code of Ethics and in compliance with internal protocols.

3.5.5 Correct information to the public administration

In order to ensure the proper exchange of information with the public administration, the CEUR Foundation commits to:

• communicate with propriety and impartiality with the institutional interlocutors at national, international, European Community and local levels using the communication channels established for this purpose;
• represent the interests and positions of the foundation in a transparent, rigorous and consistent manner.

3.5.6 Regulatory and control bodies

The CEUR Foundation fully and carefully observes the rules issued by the market regulatory Authorities and/or by supervisory and control bodies.

To ensure maximum transparency, the CEUR Foundation and its employees and contractors commit to not have conflicts of interest with employees of any Authority and their family members.

4. SUPERVISORY BODY (as per Italian Legislative Decree no. 231/01)

Established according to the dictates of Italian Legislative Decree no. 231/2001, the Supervisory Body is responsible for monitoring compliance, adequacy and the updating of the organisational-management Model for the prevention of offences pursuant to Italian Legislative Decree no. 231/01, as well as respect for the ethical principles set out in this document.

To this end it monitors the application and observance of the Model and is free to access all sources of information within the CEUR Foundation, it can view documents and consult data, and it can propose any updates of the Model and its protocols to the competent bodies.

The Supervisory Body operates with broad discretion and with the full collaboration of the Foundation’s top management, reporting at least once every six months to the Board of Directors and the Board of Auditors.

The email of the Supervisory Body is odv@CEUR.it.