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Code of Ethics Certification

1. Introduction 

Inveo (hereinafter referred to as the 'Body') is a Certification Body that, on a voluntary basis, enables its customers to carry out a correct assessment of the risks associated with the management of the personal data of natural persons subject to processing and databases, for all types of companies and, in particular, also in the pharmaceutical and health sectors with regard to the exact management of their archives in compliance with the mandatory regulations, with particular reference to the advertising of medicines (DIR 2001/83/EC) and the processing of personal data and the free movement of data (Regulation (EU) 2016/679).

Our aim is to instil in all parties concerned the right degree of confidence in the protection and reliability of the data managed in accordance with the sectoral specialities; that is, to ensure that the data used for the specific processing purposes comply with the quantity and quality required for the pursuit of the minimum objective and do not go beyond the minimum necessary

Inveo is a competent and professional impartial third party, which is able to issue the following declarations of conformity:

  • ISDP© International Scheme of Data Protection Procedure: this represents the set of control rules for verifying the correct application of the regulatory obligations laid down for individuals who process personal data in accordance with the provisions of the regulations in force. This scheme covers all types of organisations and specifies the requirements for the fair, secure and compliant management of the personal data of individuals processed. It also provides general principles and lines of control on the proper management of risks of varying likelihood and severity.
  • SGCMF© Procedure for the Conformity Assessment of Healthcare Professionals' Files Authorised to Prescribe and Dispense Medicinal Products: it is addressed to all pharmaceutical organisations that carry out "advertising of medicinal products" and that, in relation to Legislative Decree 219/06 and Regulation (EU) 2016/679 to all those organisations that need to have clear and defined rules in order to secure internal processes for the correct management of healthcare professionals' files authorised to prescribe and dispense medicinal products

Our activities generate added value for the customer because they provide strategic support in risk management, supply chain control and performance improvement with high economic returns.
In all our activities we have applied the rules laid down in the UNI EN ISO/IEC 17065 standard, i.e. 'Requirements for bodies providing audit and certification of management systems'.

 

2. Mission

Our mission is to contribute to creating a culture of compliance in the management of personal data and to become the point of reference for companies wishing to operate in full compliance with mandatory regulations in Italy and abroad.

Inveo is committed to conducting its business on the basis of the four fundamental and ethical principles of:

  1. impartiality: representation of all stakeholders in the body
  2. independence: auditors and certification/reporting committees guarantee the absence of conflicts of interest with the company to be certified
  3. fairness: European rules prohibit the provision of advice either directly or through affiliated companies
  4. competence: attestation of cultural, technical and professional competence of the personnel involved in the activities

 

3. What is the Code of Ethics

The Code of Ethics is the fundamental charter of moral rights and duties that defines the ethical-social responsibility that the Body and its staff assume both towards the Body itself and towards third parties.
It constitutes an effective means to prevent irresponsible or possibly unlawful conduct by those who operate in the name and on behalf of the Body because it introduces a clear and explicit definition of the responsibilities of each operator towards those who are directly or indirectly involved in the activity of the body, namely customers, suppliers, partners, employees, collaborators, public institutions and anyone else affected by the activity of the Body.
Its addressees are called upon to strictly and fully comply with the values and principles it contains and are required to protect and preserve, through their conduct, the respectability and image of Inveo, as well as the integrity of its economic, social and human assets.
The Code of Ethics does not, however, replace or prevail over the laws in force and the existing National Collective Labour Agreement, which retain their express and fundamental effectiveness and value.
Through the Code of Ethics, Inveo intends in particular

  1. Define and make explicit the values and general ethical principles that inform its business activities and relations with customers, suppliers, partners, employees, collaborators, administrators, public institutions and any other party involved in the company's activities;
  2. formalise the commitment to behave on the basis of the ethical principles of moral legitimacy, fairness and equality, protection of the person, diligence, transparency, honesty, confidentiality, impartiality, and protection of health;
  3. indicate to its employees, collaborators and directors the principles of conduct, values and responsibilities that it requires them to observe in the course of their work;
  4. define implementation tools and methodology.

 

4. To whom the Code of Ethics is addressed

The rules of the Code apply, without exception, to all directors and company personnel who have employment relationships with Inveo, in Italy and in all other countries in which it operates.
The term "company personnel" includes:

  • employees
  • contributors
  • consultants
  • evaluators

hereinafter jointly referred to as the "Addressees". Where necessary, the individual components are indicated separately. The Addressees of the rules of the Code are required to observe the prescriptions contained therein and to adapt their conduct and actions to the principles expressed. The directors of the company must comply with it, when proposing and implementing projects, actions and investments useful to increase the long-term economic value of the company and the wellbeing of its employees, customers and suppliers; sector managers must assume responsibility both internally and externally, strengthening trust, cohesion and team spirit; the company's employees must be committed to complying with the laws and regulations in force in the country and, in the presence of doubts and perplexities as to how to proceed, they must ask their superiors to offer the necessary directives and operational information.
Each addressee of this Code of Ethics is expressly required to know its contents, to actively contribute to its implementation and to report any shortcomings and violations.

 

5. Human and instrumental resources policies

Fundamental rights
Inveo acts in its business by respecting the fundamental rights of every individual, protecting their moral integrity and ensuring equal opportunities.
 Internally, Inveo wishes to maintain a serene working environment, in which everyone can work in accordance with the law, principles and shared values; in particular, it does not tolerate any form of isolation, exploitation or harassment on any grounds of discrimination, whether on personal or employment grounds. Any kind of discrimination based on diversity of race, language, colour, faith and religion, political affiliation, nationality, ethnicity, age, gender and sexual orientation, marital status, disability and physical appearance, economic and social condition is therefore expressly forbidden; concessions of any privilege linked to the above-mentioned reasons are also forbidden, except as provided for by the regulations in force. Inveo prohibits any disciplinary sanctions against those who have legitimately refused a work service unduly requested by any person related to it.

 

6. Value of human resources

Inveo recognises the value of its employees, respect for their autonomy and the importance of their participation in the company's activities. Honesty, loyalty, ability, professionalism, seriousness, technical preparation, the ability to work in a shared experience and the dedication of personnel are therefore among the fundamental characteristics of human resources. Recognition of salary increases or other incentive tools and access to higher roles and positions (promotions) are linked, in addition to the rules established by law and by the collective labour agreement, to the individual merits of employees, including the ability to express behaviour and organisational skills marked by the Company's ethical principles of reference, indicated by this Code.

 

7. Human resources placement policies

The company, in its professional integration policies, avoids any discrimination based on race, sex, nationality, religion, language, trade union or politics. Inveo's assessment of personnel to be hired, consultants and assessors, is based on the correspondence of the candidates' profiles with the company's needs, in compliance with equal opportunities for all those concerned. A written contract drawn up in compliance with the laws in force is prepared for each employee.

 

8. Professionalism Development

 

The management of the employment relationship is oriented towards fostering the professional growth and skills of each employee. In the evolution of the employment relationship, the company wants to ensure the necessary conditions so that the skills and knowledge of each individual can expand in accordance with these values, through:

  • a policy based on the recognition of merit and equal opportunities
  • specific and continuous training programmes.

To this end, administrators and managers are asked to pay the utmost attention to the enhancement and growth of the professionalism of their employees, creating the conditions for the development of their skills and the realisation of their potential.

 

9. Competition

Inveo, aware that free competition is an indispensable factor for its technical, professional and economic growth, intends to develop the value of competition by operating according to principles of fairness, fair competition and transparency towards all operators present on the market.
Therefore, conduct that is contrary to professional fairness, collusive, predatory, abuse of a dominant position and/or tending to create economic dependence, as well as any other conduct aimed at altering the fairness and competitive balance of the market based on the free encounter between potential demand and supply, is not allowed.
Inveo therefore respects in every country in which it operates the current rules of free competition and anti-trust legislation

 

10. Working environment and protection of privacy

The company is committed to creating a working environment that guarantees conditions that respect personal dignity, without discriminatory behaviour of any kind. The cooperation of all is required in order to maintain a climate of mutual respect for the dignity and reputation of each individual. In compliance with current legislation, the company is committed to ensuring the protection of privacy with regard to information concerning the private sphere and opinions of each of its employees, collaborators and, more generally, of those who interact with it.

 

11. Health and Safety

The company applies the current regulations on risk prevention and protection, assesses the efficiency of the prevention system and constantly monitors possible risks to staff health and safety.

 

12. Duties of personnel

Employees and collaborators undertake to comply with the obligations laid down in the Code and, in the performance of their duties, to abide by the law, and to conduct themselves with integrity, fairness, loyalty and good faith.

 

13. Company assets

Employees and collaborators are obliged to use and guard with care the assets they have at their disposal to perform their duties. Each employee and collaborator shall be directly and personally responsible for the protection and lawful use of the assets and resources entrusted to him/her for the performance of his/her duties; the misuse of assets and resources belonging to the company is not permitted.

 

14. Use of computer systems

Each employee or collaborator is responsible for the security of the computer systems used and is subject both to the applicable regulations and the conditions of the licence agreements. Employees may not install borrowed or unauthorised software on company systems, nor may they make unauthorised copies of licensed programmes for personal, company or third-party use. Employees are obliged to use the computers and IT tools made available by the Company exclusively for company purposes; consequently, the Company reserves the right to verify the correct use of IT tools in compliance with company procedures. Employees are also required not to send e-mail messages with offensive content and to use appropriate language, avoiding vulgar, blasphemous or insulting expressions.

 

15. Conflicts of Interest

Managing directors, employees and collaborators must avoid situations and refrain from activities that could set personal interests against those of Inveo. Personal interest means one's own interest, that of a member of one's family, a relative, a cohabitant or a third party in some way connected.
In order to avoid situations that create or may create a conflict of interest, employees and collaborators must in particular avoid:

  • engage in other employee, professional or business activities that compete with the company;
  • take up responsible, collaborative or other positions with individuals, companies or organisations that compete with the company;
  • entering into contracts in a personal capacity on particularly favourable terms or accepting preferential treatment from companies or suppliers with which the company has business dealings;
  • engage in activities that conflict with the proper performance of their duties;
  • accept from parties other than the company remuneration or other benefits for services to which it is obliged to render in the performance of its duties;
  • be involved in situations through which they may gain an undue advantage and/or profit from opportunities encountered during and by reason of the performance of their activities.

The person also undertakes, should he/she find him/herself in an actual or potential conflict of interest situation, to promptly inform the company in the person of the Sole Director.

 

16. Relations with customers

The company is committed to guaranteeing quality standards, based on the resources available and the contractual commitments undertaken, in the realisation of the services commissioned by public and private customers. To this end, it undertakes to develop ongoing information and cooperation relations and to use the tools of its quality system for monitoring and satisfaction surveys. In the formulation of contractual agreements with customers, it is necessary to ensure that the clauses are formulated in a clear and comprehensible manner, ensuring that the condition of parity between the parties is maintained.

 

17. Relations with Suppliers

The choice of suppliers and the purchase of goods and services of any kind must be made in accordance with the principles of competition and on the basis of objective assessments of the quality, utility and price of the supply .
The supplier shall also be selected on the basis of its ability to guarantee:

  • compliance with the Code of Ethics;
  • the implementation of appropriate corporate quality systems, where applicable;
  • the availability of suitable means and organisational structures;
  • compliance with labour legislation, including with regard to child and women labour, health and safety of workers.

In business relations with suppliers, donations, benefits, gifts, acts of courtesy and hospitality aimed at harming the integrity and independence of the parties are prohibited. Company employees must refrain in all cases from accepting or giving sums of money; the acceptance of any kind of gift is subject to the decision of the direct supervisor.

 

18. Relations with public authorities and institutions

All relations with authorities and public institutions, at any level, must be undertaken and managed in compliance with the laws and regulations in force and with the principles defined in the Code of Ethics. Institutional relations are exclusively entertained by managers who have received an explicit mandate from the company. The company, employees and collaborators shall refrain from accepting, offering or promising, even indirectly, money, gifts, goods and services, services or favours that are not due in relation to relations with public officials, persons in charge of a public service or private parties, in order to influence their decisions, with the exception of gifts or acts of courtesy and hospitality, of modest value and in compliance with normal practices.

 

19. Relations with Associations, Trade Unions and Political Parties

Inveo does not provide, either in Italy or abroad, direct or indirect contributions to finance political parties, movements, committees and political and trade union organisations, or their representatives or candidates.

 

20. Contributions to charitable associations

Inveo can only accede to requests for contributions from organisations and associations that are declared non-profit organisations with regular Articles of Association and Deeds of Incorporation

 

21. Communication with the outside world

Relations with the press, communication and information media and, more generally, external interlocutors, must only be maintained by persons expressly delegated to do so.
External communication must follow the guiding principles of truthfulness, correctness, transparency and prudence, fostering knowledge of corporate policies and the company's programmes and projects. Managers, employees and collaborators are required to maintain the confidentiality of information learnt in the performance of their duties, in compliance with laws, regulations and circumstances; they are required not to disclose or unduly request information, on documents, know-how, company operations, and in general on all information learnt in the course of their work.   Information or news concerning users and employees is also considered confidential.  
Breach of confidentiality duties seriously invalidates the fiduciary relationship and may lead to the application of disciplinary or contractual sanctions.

 

22. Internal Control

It is the company's policy to disseminate at all levels not only the existence and importance of controls, but also a mentality oriented towards exercising them. With the internal control system, Inveo intends to pursue the general objectives of effectiveness and efficiency in its operations, the safeguarding of company assets and resources, compliance with laws, regulations and internal procedures, and the reliability of accounting and financial data. Each employee therefore has the specific responsibility, within the scope of his or her activity, to implement, maintain and monitor the proper functioning and effectiveness of the internal control system.

 

23. Accounting Transparency

Every operation and transaction must be properly recorded, authorised, verifiable, legitimate, consistent and appropriate. All actions and transactions must be properly recorded and it must be possible to verify the decision-making, authorisation and execution process. Accounting transparency is based on the accuracy, completeness and authorisation of the basic information for the relevant accounting records. Each employee is obliged to cooperate in order to ensure that management events are correctly and promptly represented in the accounts.
Adequate supporting documentation of the activity carried out is kept for each transaction in order to allow for the easy recording of accounts, the identification of the different levels of responsibility and the accurate reconstruction of the operation, also to reduce the likelihood of errors of interpretation. Each record must reflect exactly what is shown in the supporting documentation. All documentation must be promptly and systematically filed so that the relevant accounting picture can be reconstructed at any time: in addition to filing in the appropriate paper binders, if provided for, documents must also be stored in electronic media from which they can be quickly traced and viewed using special document software.
In any case, it is the duty of each employee to ensure that the documentation relating to his or her activity is easily traceable and ordered according to logical criteria.
In any case, the company payments to be made shall be exclusively commensurate with the service and modalities indicated in the contract and may not be made to a party other than the contractual counterparty.
The use of company funds for illegal or improper purposes is strictly prohibited. Payments not based on properly authorised company transactions or illegal forms of remuneration shall not be made to anyone for any reason. Any neglect, omission or falsification of which employees become aware shall be promptly reported to management.

 

24. Compliance with the Code of Ethics

Inveo undertakes to facilitate and promote the knowledge of the Code of Ethics by its addressees and to scrupulously supervise its observance, providing adequate information, prevention and control tools to ensure, in any case, the transparency of the operations and conduct implemented, intervening, if necessary, with corrective actions. Employees are obliged to promptly report to the company management any news they may learn of a breach of the rules of the Code of Ethics, so that the company may promptly prepare all the necessary protection initiatives and all interventions that are in any case useful to bring back the work to the rules of ethics and to restore compliance with the law, where breached.

 

25. Reporting violations

In order to ensure the effective application of the Code, Inveo requests all interested parties, internal and external, to report, in writing and not anonymously, any non-compliance with this Code and any possibility of breach thereof, from whomever they may come, to their manager.
The company protects the authors of reports against any retaliation they may face for reporting incorrect behaviour, keeping their identity confidential (without prejudice to legal obligations).

 

26. Sanctions

Compliance with the rules of the Code must be considered an essential part of the obligations provided for employees in Article 2104 of the Civil Code, as well as an essential part of the contractual obligations provided for with reference to other Addressees. A serious and persistent breach of the rules of the Code damages the relationship of trust established with the company and constitutes a breach of the obligations arising from the employment relationship, with all contractual and legal consequences. Consequently, disciplinary actions and compensation for damages are envisaged, without prejudice, for employees, to compliance with the procedures provided for by the Workers' Statute and the CCNL. For the purposes of this Code, the term 'serious breaches' refers to all those persistent breaches from which the company incurs sanctions.
This is without prejudice to further responsibilities of a criminal, civil and administrative nature that conduct against the provisions of this Code may entail for the offender.

 

27. Disclosure of the Code of Ethics and Conduct

This Code is approved by the Corporate Bodies and brought to the attention of company personnel and those with whom the company has contractual or institutional relations 
The company promotes knowledge of and compliance with the Code among all directors, shareholders, employees, collaborators in various capacities, consultants, customers and suppliers, and users. The heads of organisational units must make themselves available to provide operators with the clarifications necessary for the interpretation of the indications set out in the Code of Ethics.
All Addressees are required to observe and, to the extent of their competence, enforce the principles contained in the Code of Ethics.

 

References: Legislative Decree No. 231 of 8 June 2001 and subsequent updates