Code of Ethics



This Code of Ethics was prepared by Diamant Srl in order to express the values and principles that the company recognizes as its own, in the belief that it is also evaluated on these aspects in addition to the quality of its products and the efficiency of its services.

This Code expresses the ethical commitments and responsibilities inherent in the corporate actions undertaken by Diamant Srl and all collaborators, whether they are directors or employees in every sense of the enterprise.

This document is drawn up to be used as a tool for Social Responsibility and for the active and conscious management of ethical issues in everyday work activities, so it is a "governance tool." It is also hoped that the Code of Ethics can be a useful tool in facilitating organizational decisions and to make the individual responsibilities of managers, executives, workers, collaborators and suppliers explicit.

The company also wants to remind people of the importance of internal regulations in order to continue working in an atmosphere of respect and serenity.

The Company

Diamant Srl is a company that combines its manufacturing vocation with its ability to innovate, develop the product and industrialize it using the latest technologies.

Active mainly in footwear manufacturing, Diamant Srl creates products starting from research and development and continuing on to their industrialization and marketing worldwide.

Definition of ethical behavior: what is ethics?

Taking the definition provided by the European Community’s Green Paper "Promoting a European Framework for Corporate Social Responsibility", a code of ethics "sets out minimum standards and attests to the commitment made by the company to observe them and to have its contractors, subcontractors, suppliers and dealers observe them”.

"Ethics" expresses the set of rules of conduct - both public and private - followed by a person or group of people. While referring to an abstract universe (made up of principles and values), its scope is far from theoretical. It concerns everyday life and is translated into rules of conduct.

Thus, ethical behavior is defined as the way that the individuals who constitute the organization act, consistent with the company's values and principles.

In the field of business ethics, the concept of individual responsibility and awareness is inevitably linked to that of "Corporate Social Responsibility" or "Corporate Citizenship".

At Diamant S.r.l., Corporate Social Responsibility is configured as the ability to integrate its business activities with the respect and protection of the interests of all partners and individuals with whom it deals, with the safeguarding of environmental resources and their preservation for future generations. In no way is there a belief that acting for the benefit of the company can justify the adoption of behavior conflicting with shared principles and values.

The primary purpose of the Code of Ethics is to make common and widespread the values in which the company recognizes itself, at all levels, ensuring that everyone, whenever they are called upon to make a decision, is clearly reminded that at stake are not only their own interests, rights and duties, but also those of others.

The goal set by Diamant S.r.l. is also to introduce ethical evaluation, both in deciding one's own behavior and in evaluating the behavior of others, uniting the ethical sphere with the managerial sphere, individual responsibilities with those of the company, and the personal sphere with the organizational sphere, translating reasoning into concrete ethical action.

Scope and recipients of the code

The recipients of the Code are all those who in various capacities and with different responsibilities achieve, directly and indirectly, the purposes of Diamant Srl.

The provisions contained in the Code of Ethics are applied by all parties (employees, collaborators, service companies and third parties) who contribute to the mission of the company by following the principles of sound and prudent management in compliance with regional, national and EU laws, as well as internal policies, plans, regulations, and procedures.

The company undertakes to equip itself with the most appropriate tools so that the code of ethics is effectively disseminated and fully applied by recipients and third parties. It is the duty of all recipients to know the contents of the code of ethics, understand its meaning and take action to seek any clarifications regarding it.

The Code of Ethics of Diamant Srl is an ideal alliance that the company makes with its human resources and key external stakeholders.
 It is therefore the duty of every resource, including consultants, suppliers, customers and anyone who has dealings with the company, to comply not only with applicable laws and regulations, but also with this Code of Ethics.


With the intention of maintaining the craftsmanship that has always distinguished it and its "Made in Italy" identity, Diamant Srl adopts an original business model capable of combining innovation and tradition, pursuing excellence and transforming it into a competitive advantage in the markets, while also paying attention to the issue of economic, social and environmental sustainability of the business.

Ethical values

In pursuit of its mission, Diamant Srl is aligned with the objectives and ethical foundations outlined below:

Correctness and Transparency: all operations, actions and behaviors put in place in the performance of work activities are marked by fairness, transparency, utmost clarity and truthfulness, and legitimacy in formal and substantive aspects;

Honesty: in dealings with employees, suppliers and third parties;

Impartiality: in making its decisions, the company is inspired by the protection and promotion of human rights by rejecting any form of discrimination in relation to the age, sex, health conditions, race, nationality, political opinions and religious beliefs of its interlocutors;

Innovation: aiming at the continuous updating of methodologies and processes targeted at achieving the highest quality standards of services and products provided, taking into account the economic-financial and fiscal policy guidelines;

Entrepreneurship: business objectives, promotion and implementation of projects and investments must be geared toward cost-effectiveness and efficiency to provide solutions and services with a high quality to cost ratio and to increase the company's asset, management and technological values;

Mutual respect: in the performance of all recipients' activities;

Traceability: all activities of the company are properly recorded so that the processes of decision-making, authorization and performance can be verified;

Customer Satisfaction: firm in its underlying ethical principles, the company affirms the importance of achieving total customer satisfaction with the products provided; To achieve this goal, the company pursues the establishment and maintenance of high quality standards in relation to the market, constant commitment to process and product innovation, and monitoring of customer satisfaction;

Value of human resources: the company promotes and protects the value of human resources in order to maximize satisfaction and enhance their professionalism, while respecting the dignity of the person. It promotes "know how" and "knowing how to get things done" as initiatives for developing and maintaining leadership in its field. The value of human resources is to be protected, also through the continuous enhancement of technical and professional skills, thereby fostering the exchange of information and experience through communication actions aimed at sharing knowledge and corporate values;

Integrity of people: fostering the physical and moral integrity of people through healthy and safe working environments and working conditions that respect individual dignity;

Corporate social responsibility: to consciously and responsibly manage its activities in accordance with relevant national and international regulations, taking all necessary measures to reduce the impact of its actions, seeking the continuous balance between economic initiatives and environmental and social needs;

Personal Responsibility: commitment to establishing a trusting relationship with one's colleagues and, more generally, with all stakeholders. It is considered essential to engage loyally and effectively to achieve the company's goals with an awareness of one's duties and responsibilities.

Principles inherent in the management of the business

The company implements administrative, accounting and financial management aimed at ensuring business continuity in the interest of employees, recipients, third parties and in general all stakeholders in the company. The company's accounting system ensures that every transaction of a financial nature is recorded in accordance with the principles, criteria and methods for preparing and keeping accounts dictated by current regulations.

Each accounting transaction must therefore be supported by appropriate documentation showing the activity performed, so as to enable:

• the easy accounting entry
• the identification of the origin or formation of the documents
• the accounting and mathematical reconstruction of transactions.

The company requires that the inclusion of all items in the financial statements results from unconditional compliance with all applicable regulations on the formation and valuation of financial statements.

Specifically, employees assigned to process accounting balances are required to control or promote the control of all accounting operations prodromal to the production of balances, also in order to reduce possible errors.

Furthermore, since the company adheres to values of honesty and transparency, anyone involved in any capacity in the preparation of company documents, whether accounting or administrative, is required to produce only material facts that are true and must not in any way conceal or alter information about the company's economic, financial, employment or asset situation.

Anyone who becomes aware of omissions, falsifications or neglect of accounting records or supporting documentation must immediately notify the Ethics Committee and Management.

General Principles

Every employee and collaborator must act loyally and in good faith by complying with the obligations signed in the employment contract and ensuring active and intensive cooperation, according to the directives of the company; as well as knowing and observing the rules contained in this code of ethics, imprinting their conduct with respect, cooperation and mutual collaboration.

All actions, operations, negotiations and, in general, behaviors put in place in the performance of work activities must be marked by the principles of honesty, fairness, integrity, transparency, legitimacy, clarity and mutual respect as well as being open to checks and controls in accordance with current regulations and internal procedures.

All activities must be carried out with professional diligence. Each person must make professional contributions commensurate with their assigned responsibilities. Directors accept office when they believe they can devote the necessary time to the diligent performance of their duties, also taking into account the number of directorships or auditorships they hold in other companies. Personnel must be familiar with and implement the company's provisions on environmental protection, occupational safety and hygiene, and privacy protection in relation to the function performed and/or level of responsibility assumed.

The worker, in the performance of his or her duties, must scrupulously follow the instructions given by his or her superiors and, in dealing with fellow workers, must maintain proper and polite behavior. The employee is also obligated to use courteous and respectful manners with the public and with the company's customers and to conduct himself or herself in accordance with civic duties. The right-duty of everyone to expect and to respect decorum in clothing and hygiene at workplaces, and to comply with the rules for separate waste management is reminded.

The protection of company-owned assets

Every employee and collaborator is required to safeguard the company's assets by guarding the company's movable and immovable property and equipment with the utmost diligence.

Every employee is required to work diligently to protect company assets through proper and responsible behavior and in line with the operating procedures prepared to regulate their use, accurately documenting their use.

In particular, each employee must scrupulously use the assets entrusted to him or her, avoiding improper uses of company assets that may cause inefficiency or harm to the company's interest; in addition, he or she has a duty to promptly inform the appropriate functions of any threats or harmful events.

Every employee of Diamant S.r.l. is required to work with the diligence and efficiency necessary to protect and exploit the company's resources, ensuring their use is consistent with the company's interest. Likewise, it is the responsibility of employees and contractors not only to protect these assets, but also to prevent their fraudulent or improper use for their own or third parties' benefit. Every employee shall guard said equipment, carry out its proper maintenance, and store and use it with normal care and diligence. The above also includes company vehicles (cars, vans, etc.).

It is the worker's specific obligation to keep tools, utensils, cabinets, in general everything entrusted to him or her in good condition (including personal protective equipment such as goggles, masks, gloves, etc.).

Occupational health and safety policy

Diamant Srl intends to commit itself to a policy that places both external and internal customers at the center of its activities, understood in its fullest sense, adhering to compliance with all legal requirements pertaining to Occupational Health and Safety and other requirements established by the organization.
To this end, this Code of Ethics refers to the "Occupational Health and Safety Policy"

Compliance with the Code of Ethics

Directors, employees and collaborators of the company base relationships on cooperation and trust. To this end, daily behaviors are guided by compliance with the rules contained in this Code. Any behavior that does not comply with the Code of Ethics is tantamount to a breach of the covenant of trust and therefore should be brought out and reported in the prescribed manner.

Sharing the Code

Diamant Srl is committed to sharing this Code of Ethics with all stakeholders and requires all those who, in various capacities, collaborate in the company's activities to conform their behavior to that described in this Code.

Customer relations

A customer is defined as anyone who benefits in any capacity from the enterprise's products or services.

The company pursues its business success in domestic and foreign markets by offering quality products, with constant attention paid to the specific needs of each individual customer. Commercial policies are aimed at ensuring the quality of goods and promoting the complete satisfaction of customers' needs. It is therefore the obligation of all recipients of this code to:

• Observe internal procedures for handling customer relations;• Provide, with efficiency and courtesy and within the limits of contractual provisions, high quality products that meet the reasonable needs of customers;
  • Provide accurate and truthful information about products, adhering to principles of truth and fairness, so that customers can make informed decisions.

    Attention to customer needs: Diamant Srl imprints its relationship with customers on helpfulness, respect, courtesy, participation and commitment to their satisfaction. Recognizing the value of listening and dialog, tools and channels are established and promoted to ensure the timeliness and quality of information and communication to customers, increasing the degree of mutual cooperation and improving the quality of services and relationship.

    Information and communication to customers: Diamant Srl undertakes to inform the customer in a complete and timely manner about the features, functions, costs and risks of the service offered. In particular, communications, contracts, documents, and any other information issued by the Company should be clear and simple, formulated in a language that is as direct and commonly used as possible; complete and truthful, so as not to overlook any element relevant to the decision for the current or potential customer; and respectful of the provisions on the protection of privacy and the general inspiration of this Code.

    Product quality and safety: Diamant Srl guarantees its customers products and related services meeting the highest standards of quality and safety and to periodically monitor perceived quality.

    Management and communication of the quality of service provided: To this end, the Company undertakes to: adopt quality management systems and establish specific service improvement programs; provide institutions with the information necessary to understand any risks to the safety of communities related to the company's activities and to the quality of the service provided; promote service quality awareness and training activities; and make known to customers how to make complaints and provide appropriate responses to complaints.

    Fairness in contracts and business dealings: Diamant Srl guarantees fairness in contracts and business dealings by committing itself to ensuring that the agencies conform their behavior and that of the individuals assigned to them to the same rules of fairness that the company adopts with respect to its customers.
  • Relations with employees and collaborators

    For the purposes of this Code, an employee and/or collaborator is defined as a person who, beyond the legal qualification of the relationship, has a direct working relationship with Diamant Srl and aimed at achieving the purposes of the company.

    General principles and rules of conduct:

    Relationship between colleagues and attention to employee privacy: Every employee and collaborator is called upon to assume towards their colleagues an attitude marked by respect, protection of personal dignity, cooperation, and human solidarity. Diamant Srl respects the privacy of its employees and collaborators, and identifies ways to pay attention to their needs in difficult situations that may impede the normal course of work.

    Gifts, giveaways and benefits: Gifts and giveaways of a value exceeding reasonable limits or inconsistent with normal labor relations create situations of conditioning and, therefore, interference in the conduct of the employment relationship, which must be free from obligations of gratitude.

    Therefore, Diamant Srl prohibits its collaborators (as well as their family members) from accepting gifts, benefits or favors offered by people with whom they have a working relationship, which may compromise the independence of judgment of the same or at least create suspicion that the same has failed. Cash, tangible goods (such as travel, watches, jewelry, exceptional wines, leather goods, valuables, clothing, smartphones, hi-tech devices, etc.) and also services and discounts on purchases of goods or services are considered benefits. Instead, normal business courtesies include, for example, small gifts such as flowers, gadgets, books, sweets etc. Any invitations to lunch or dinner from suppliers or business partners must never affect the propriety of professional relations and must always allow the sphere of personal and business relations to be kept separate. It is permissible to use, even for personal use, points accumulated during business trips offered by airlines or hotel chains. However, it is not permissible to request or change airlines, flights, or other types of reservations for the sole purpose of accumulating points or mileage, particularly if doing so results in additional costs to the company. All reservations must in all cases conform to the general rules of the company's travel policy, in accordance with the general principles of sobriety and self-responsibility.

    Abuse of alcoholic or narcotic substances: The company prohibits each employee or collaborator from abusing alcoholic substances during working hours and before performing work activities; it also prohibits the taking during working hours and/or before performing work activities of drugs, hallucinogenic substances or substances that otherwise prevent or hinder the regular performance of work activities. In any case, the company discourages the abuse of alcohol and the use of drugs by each employee or collaborator even outside working hours and regardless of the influence of such conduct on the regular performance of work activities. States of chronic alcohol and drug addiction that affect work performance and are likely to disrupt normal work performance will, however, be equated with the previous cases, regardless of whether the employee or collaborator has not abused alcohol or taken drugs during working hours.

     • Smoking: The company enforces compliance with the prohibitions stipulated in the relevant regulations and in any case in places where this may generate danger to the safety of people and the healthiness of the environment.

    Discrimination and harassment

    Diamant Srl guarantees equal opportunities for all its employees at all levels. The company is committed to combating all forms of discrimination or harassment, promotes and rewards people by considering only results and work performance, and fosters the consolidation of a corporate climate aimed at tolerance and respect for human dignity. It is therefore forbidden to:

    • Engage in behavior that may create an intimidating or offensive atmosphere toward colleagues or co-workers;
    • Engage in behavior that may offend the sensitivities of others, including attitudes of a sexual nature (such as unwanted physical contact, gestures and statements with sexual connotations, and displaying even images);• Take retaliatory action against any employee who in good faith opposes or reports any instances of discrimination, harassment or personal offense.

    Abuse of authority

    The hierarchical superior will not request personal favors or any other behavior from his or her collaborators that is not provided for in labor contracts and the rules of this Code.

    Promotion and protection of employment

    The company is committed to adopting strategies that combine business growth and profitability with the protection and development of employment - both direct and satellite - and to promoting quality of work, consistent with the constraints of the external economic scenario.

    Bargaining and workers’ representation

    The company wants to inspire decisions and behavior toward employees with strict compliance with regulations and collective agreements, in respect and cooperation with freely elected union representatives and in a constructive spirit of labor union relations.

    Selection and Inclusion

    The company is committed to developing the aptitudes and potential of personnel in the performance of their duties so that the abilities and legitimate aspirations of individuals find full realization in the context of achieving the company's objectives. For this reason, too, the company is committed to ensuring equal employment opportunities for all employees on the basis of professional skills and qualifications without discrimination and/or favoritism. To this end, the company's human resources are engaged following criteria of merit, effectiveness and efficiency, in compliance with the law, the collective bargaining agreement applied and the relevant ethical principles.

    The selection process is carried out with respect for equal opportunity and the individual, in a structured manner that is clearly explained to the candidate. The company is committed to providing the candidate with correct and complete information about the organization and the position for which he or she will be evaluated.

    The candidate is required to correctly convey to the recruiter all the relevant information to make the selection process effective and efficient. The company is also committed to implementing all activities that facilitate the newly hired employee's inclusion in a collaborative environment that fosters his or her professional growth.

    Enhancement of human resources

    The company is committed to promoting diversity and ensures a work environment in which everyone can collaborate by expressing their professional aptitude in a context of shared, promoted and respected rules. The company, in the employment relationship, measures skills, potential and commitment, using clear and uniform evaluation criteria.

    Training and development

    Diamant Srl recognizes the importance of training as an indispensable factor in increasing the competence of employees and the value of the company.

    To this end, it designs and implements an annual training plan for its employees and collaborators, combining the company's growth needs with the training needs expressed by workers, and providing the appropriate tools for refresher courses and professional development.

    Work standards (work organization: tasks, hours and shifts, time management)

    Diamant Srl provides for overall planning of activities, ensuring that each person occupies the most appropriate role, maximizing the utility of the organization, while respecting equal opportunity. To this end, there is a constant updating of the system of organizational responsibilities, competences and functions performed by existing staff.

    Employees agree to assume responsibilities related to their assigned duties and to act cooperatively throughout their tenure with the company. It is the obligation of each collaborator to adhere to assigned hours and shifts and to report absence in a timely manner.

    All managers are expected to exploit the working time of employees, who should only be asked to perform tasks consistent with their activities and the needs of the company. Likewise, all workers have a duty to pursue, in the use of their time, the maximum efficiency of the organization and to propose improvements in this regard.

    The duration of weekly work activity is determined by the national bargaining agreement of the Footwear Industry. Compliance with working hours as defined by management is the obligation of the employee; failure to do so shall be deemed grounds for disciplinary action.

    Working hours include clocking in and clocking out to validate one's attendance, ensuring that one is at one's workstation at the designated time.

    Conflict of interest

    All employees and collaborators must avoid situations in which conflicts of interest may arise. Likewise, they must refrain from taking personal advantage of the position, information and discretionary power associated with their function.

    Relationship with the media

    The company recognizes the information role played by the mass media toward the public. To this end, it undertakes to cooperate fully with the media, without discrimination, while respecting each other's roles.

    The company's communications to any media organization must be truthful, clear, transparent, unambiguous or instrumental; they must also be consistent, homogeneous and accurate, in accordance with the company's policies and programs.

    Relations with the press and other mass media are reserved for the appropriate corporate bodies and functions. Each recipient is required to comply with the principles set forth in this Code of Ethics on any occasion in which, for any reason, he or she has dealings with the mass media or makes through them any statement involving, even potentially, any reflection on the image of the company and/or the company.

    Relations with suppliers

    Suppliers are the people and companies that, in various capacities, individually or as part of a chain, provide goods, services, work and resources necessary for the implementation of activities and the delivery of products and services, contributing to the achievement of objectives. All of them are required to adopt the purposes and principles of this Code.

    The principles applied to customer relations must characterize the company's business relations with its suppliers, with whom it is committed to developing relationships of fairness and transparency.

    In particular, the criteria for selecting them to award contracts are subject to objective and transparent assessments of their professionalism and business structure, quality, price, mode of service performance and delivery time.

    Those charged with the selection of suppliers, in the performance of the functions for which they are responsible, must act in the exclusive interest of the company, refraining from engaging in conduct in which a situation of conflict of interest may even potentially be recognized, or which may constitute a criminal offence or other offence.

    They must also scrupulously observe the contractually stipulated conditions, maintaining relations with suppliers in accordance with good business practices, promptly bringing to the attention of their superiors and management any problems that have arisen in relations with suppliers, so as to assess their consequences for the company's goods and services procurement system.

    The remuneration to be paid to the supplier shall be commensurate exclusively with the performance specified in the contract, and the relevant payments may in no way be made to parties other than the contracting party, nor in a third country other than that of the parties or of execution of the contract.

    Suppliers are made aware that they are to conduct their business by following standards of conduct consistent with those set forth in this Code.

    Relationships with the territory, communities and institutions

    The term "territory" means a specific physical space with its natural and historical features, communities, institutions and other forms of social organization. The term "institutions" ordinarily refers to public organizations.

    Relationship with the environment: environmental policy

    Management provides human, instrumental and economic resources to pursue the goals of continuous improvement of its environmental impact as an integral part of its business and as a strategic commitment to the company's broader goals. See the "Environmental Policy" of Diamant Srl.

    Relations with the public administration

    Relations with the Public Administration, public officials or persons in charge of a public service must be inspired by the strictest compliance with the applicable legal provisions and regulations and may in no way compromise the integrity or reputation of the company.

    The assumption of commitments and the management of relations, of whatever nature, with the Public Administration, public officials or persons in charge of a public service are reserved exclusively for the company's organizational structures appointed for this purpose and authorized personnel.

    In general, recipients shall demonstrate the utmost helpfulness and cooperation in relations with the Public Administration, ensuring the exchange and transmission of information and data in any form, electronically included, in compliance with current regulations and company procedures and directives.

    In the course of a business negotiation, request or business relationship with the Public Administration, recipients must not take (directly or indirectly) the following actions:

    • Investigate or propose employment and/or business opportunities that may benefit Public Administration employees in their personal capacity;
    • Solicit or obtain confidential information that could compromise the integrity or reputation of either party.

    Relations with institutions

    Diamant Srl develops collaborative and communicative relationships with institutions concerning:

    • The regulatory and administrative activities related to business activities;
    • Environmental protection;
    • Risk prevention.

    The company's directors, employees and contractors act toward institutions with integrity.

    Relations with regulatory authorities

    The company undertakes to provide the national and local authorities in charge of monitoring and regulating services with all requested information in a complete, correct, adequate and timely manner.

    Economic relations with political parties, trade unions and associations

    The company does not make contributions of any kind, directly or indirectly, to political parties, movements, committees, or political and labor organizations, or to interest-bearing associations in general - except those whose activities are for the benefit of employees - or to their representatives or candidates, with the exception of contributions due on the basis of specific regulations applicable to the conduct of the company's business and the exercise of the employer-employee relationship. In addition, the company refrains from putting any direct or indirect pressure on political figures, nor does it accept referrals for hiring, consulting contracts or the like. Code recipients may not engage in political activities on Diamant Srl premises or use company property or equipment for that purpose. Recipients should also make it clear that any political opinions, if any, expressed by them to third parties are strictly personal and do not, therefore, represent the position of Diamant Srl.  

    Support for social and cultural initiatives

    Participation in external associations, initiatives, events or meetings is favored subject to compatibility with the performance of employees' work or professional activities.

    Regarding active participation in association initiatives, events or external meetings of corporate interest of any kind, employees called upon to illustrate or provide outside data or news regarding Diamant Srl's objectives, activities, results and points of view are required to obtain prior authorization from their supervisor regarding the lines of action they intend to follow, the texts and reports prepared, and to share the contents with the organizational structure responsible for Communication. Should the areas covered involve, directly or indirectly, the customer, the company will ensure that prior permission is sought from the customer both with regard to participation and the dissemination of the relevant content.

    The issuance of articles, studies, reports and insights is carried out in compliance with the rules inherent in the protection of copyright and the regulation of information and communication activities of public administrations.

    Relations with judicial authorities and agencies with inspection powers

    Diamant Srl acts in accordance with the law and promotes, within the limits of its competence, the proper administration of justice. The company, in the course of its activities, operates lawfully and fairly, cooperating with representatives of the judicial authority, law enforcement agencies and any public official with powers of inspection. Diamant Srl requires recipients to provide utmost helpfulness and cooperation to anyone who comes to conduct inspections and audits on behalf of INPS, the Italian Ministry of Labor and Social Policies and any other public administration. In anticipation of a judicial proceeding, investigation or inspection by the public administration, it is forbidden to destroy or alter records, minutes, accounting entries or any kind of document, or to lie or make false statements to the competent authorities.

    Internal controls

    "Internal controls" means all the tools necessary or useful for directing, verifying, and pursuing the company's activities with the aim of ensuring compliance with laws and company procedures, protecting company assets, effectively managing company activities, and clearly providing true, correct, and reliable information about the company's assets, liabilities, income, and financial position as well as identifying and preventing risks that the company and its collaborators may incur.

    It is the company's task to promote, at all levels, an internal culture characterized by awareness of the existence of controls and oriented toward the exercise of control.

    Employees must, to the extent of their competence, contribute to the proper functioning of the control system;

    The tasks of supervising the observance and updating of the Code of Ethics, disseminating the ethical principles and values of the company, proposing improvements to the provisions of the Code, and clarifying any doubts of interpretation and application are entrusted to the Ethics Committee.

    Reports of any violations of the Code should be reported to the Ethics Committee in the manner established by company procedures.

    Implementation of the Code

    Specific duties for managers

    Anyone who serves as a leader, manager or executive must set an example by carrying out his or her activities in accordance with the principles and rules of conduct contained in the Code and, by his or her actions, must demonstrate to other employees that compliance with the Code is a fundamental aspect of their work, making sure that everyone is aware that business results should never be separated from compliance with the principles of the Code of Ethics.


    Each business function oversees and ensures the adherence of its actions and activities to the principles and rules of conduct in this Code of Ethics. In addition, each function is responsible for carrying out line controls in its area of responsibility, detecting non-compliance that has occurred internally and reporting it to the Ethics Committee.

    Reporting violations

    Reports of violations of this Code, or alleged violations, must be made by each employee to his or her immediate supervisor or to the Ethics Committee.


    Failure to comply with the rules of conduct contained in this Code of Ethics will be relevant for the imposition of disciplinary sanctions up to dismissal, according to applicable national regulations and without prejudice, however, to the possible adoption of different sanctioning measures related to responsibilities of another nature. The application of disciplinary sanctions is irrespective of the outcome of any criminal or civil proceedings, as the rules of conduct imposed by the Code of Ethics are effective regardless of the crime and/or misdemeanor that any improper conduct may result in.

    No conduct that is unlawful or otherwise in violation of the provisions of this Code or even merely illegitimate or improper shall be justified or considered less serious, even if done in the interest or advantage of Diamant Srl.


    This revision of the Code of Ethics comes into effect as of 01/13/2020.

    Ethics Committee for the dissemination and implementation of the Code

    All powers regarding the dissemination and implementation of this Code are reserved for the board of directors, which appoints a special Ethics Committee composed of three members, including at least one Director of Diamant Srl, a member of the Human Resources Department and an expert in social responsibility and the topics covered by Italian Legislative Decree 231/01. At least one member is external. The committee holds office for three years and its members are eligible for re-election. At its first meeting, the committee elects a chairman from among its members.

    Promoting the Code of Ethics Promotion

    The Ethics Committee, together with the management of Diamant Srl and the management bodies of the companies, promotes awareness and implementation of the Code at all levels of the organization.

    Advice on Code interpretation and ethics training

    Even a single member of the Ethics Committee may be asked for opinions regarding the content and compliance with the Code. Diamant Srl undertakes to take on periodic initiatives to train employees and collaborators on the purposes and contents of the Code, particularly upon their entrance and hiring, as well as information and awareness-raising initiatives on the same issues.

    Procedures for the operation of the Ethics Committee

    Procedures for the operation of the committee are defined by the committee and submitted to the Board of Directors for approval. In particular, relations with the corporate management will be ensured directly by the committee chairman. Whenever the Ethics Committee sees the need for changes or updates, they will be submitted to the board of directors for approval once resolved.

    Limits to the competence of the Ethics Committee

    It is not within the committee's competence to rule on the interpretation of rules of law or contractual clauses.


    The Ethics Committee is responsible for the use of any information pertinent to the investigation. The submitter of a complaint must be informed about the use of any information brought to the committee's attention.

    Filing of deeds and minutes

    All documentation pertaining to the committee's activities will be kept in the designated rooms provided by Diamant Srl and which guarantee security and confidentiality.

    Relationship between Committee and Board of Directors, Relationship between Committee and Company Departments

    The actions of the committee will be periodically reported to the board of directors, and a specific meeting of the board will be held annually, at which a general assessment of the ethical condition of the company will be made and the next lines of activity will be defined.

    If the committee identifies cases that fall under the jurisdiction of laws, contracts or regulations, it shall refer the case and its handling to the appropriate bodies. Whenever the committee identifies a relationship with regulations, contracts or rules pertaining to a specific management area, it may make contact with those responsible, informing them of the facts.

    Communication to interested parties

    The committee must inform the complainants of the result of its assessments, duly substantiated. The committee is not obliged to make the investigation records public.

    Validity of the Code

    This Code is valid until revoked or revised. Periodically, the Code of Ethics will be subject to review and possible revision through the involvement of all stakeholders and with the coordination of the Ethics Committee.