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Code of ethics


The Code of Ethics is the document through which Officina Futuro Fondazione W Group (now Foundation) expresses the principles, values, commitments and ethical responsibilities that inspire its business and that govern the entire organization and the behavior of all interested parties, as will be stated below. The code of ethics stems from the desire to share the principles that drive relationships with the foundation's stakeholders and represents a system of rules and values to be observed by all those who work in the name and on behalf of the Foundation, both with reference to internal relationships and with external subjects. In order to define, with clarity and transparency, the values that inspire the conduct of its activities, the Foundation has engaged in a discussion with the employees of W Group (founding member) who, since the day the Foundation was created, they feel motivated to share the initiative. This identification has developed on different levels: first, our stakeholders have been defined, for each of them, the values to be shared have been identified as well as the commitments to assume, the challenges to be posed, and - finally - the objectives to be achieved. Each interlocutor will have dedicated attention and clear processes to optimize energy and meet everyone's needs. Officina Futuro Fondazione W Group aims to promote and strengthen projects for social, civil and economic through concrete actions to bring socially disadvantaged people closer to the world of work. As stated in the statute, the Foundation “operates in the field of work orientation, education, education and training, intending to promote the implementation of initiatives that allow socially disadvantaged people to find a place, to remain in the world of work and to improve their working condition. The Foundation, through its activities, intends to promote greater social awareness aimed at removing disparities in treatment between genders in the workplace.”


The Code of Ethics applies to the Foundation in its entirety. The set of ethical principles and values expressed in the Code must inspire, and therefore be applied, in the activities of all those who work in various capacities and sizes in the Foundation, or in all its structures, taking into account the importance of the roles, the complexity of the functions and the responsibilities entrusted to them for the pursuit of the Foundation's goals.
In promoting its activities, the Foundation is mainly inspired by the following values identified in collaboration with all W Group employees:
1. Equality, availability, equity, inclusiveness, security and non-discrimination underpin our actions towards the beneficiaries of the Foundation's projects.
2. Collaboration, sharing, growth and trust accompany relationships with our suppliers.
3. Reliability, transparency, trust and foresight relate us to our Partners.

And more generally, the values that the foundation supports and shares are:
• Legality
• Equal opportunities
• Confidentiality
• Responsibility
• Health and Safety
•Innovative approach
• Active listening


3.1 Compliance with the law and regulations

Legality is an essential principle for all those who work in the Foundation. The pursuit of the Foundation's interest can never justify conduct contrary to the principles of fairness, moral integrity and honesty.
The Foundation places as an indispensable principle respect for the Italian Constitution, laws and regulations.
In this sense, no behavior contrary to the above-mentioned rules, anyone who does so, even if motivated by the pursuit of an interest or advantage for the Foundation itself, can be considered tolerated and justified and will entail the adoption of sanctioning measures.
The Foundation requires that this conduct be followed also by individuals who, for whatever reason, maintain relationships with it and undertakes not to start or continue any collaborative relationship with those who have not made the same commitment.

3.2. Equality and rejection of all discrimination

In its relations with all its partners, the Foundation avoids any discrimination in full respect of art. 3 of the Constitution, based on the age, racial and ethnic origin, nationality, political opinions, religious beliefs, sex, sexuality or the state of health of its interlocutors.
The Foundation supports equal opportunities through projects and paths capable of generating autonomy and approach to the world of work, in compliance with the principles of non-discrimination.
This attention to people is expressed through paths to support frailty, inclusion of diversity, enhancement of potential. The Foundation, by its nature, affirms the fundamental importance of human resources, understood as the combination of knowledge, skills and attitudes of employees and collaborators, establishes with its employees, collaborators and project partners, relationships characterized by mutual trust and the full and profitable fulfillment of their respective contractual obligations, in full respect of the rights and duties of workers.
All Employees, Collaborators and third parties in general who have relationships of any capacity with the Foundation have the right to be treated as subjects with rights and values, with a spirit of understanding and equal respect and consideration, and not to suffer directly - or indirectly - any discrimination.

3.3. The protection of health and safety

The Recipients of this Code contribute to the process of preventing risks and protecting health and safety in the workplace, without prejudice to individual responsibilities under the applicable legal provisions on the subject. They must also maintain a climate of mutual respect for the dignity, honor and reputation of each, while also respecting the organization that exists within the Foundation.

3.4. Honesty and transparency

The Foundation operates in compliance with professional ethics and internal regulations.
The pursuit of the company's interest can never justify conduct contrary to the principles of fairness and honesty; also for this reason, any form of benefit or gift, received or offered, that may be understood as a tool aimed at affecting the independence of judgment and conduct of the parties involved, is rejected.

Every employee and/or collaborator must act loyally and in good faith, complying with the contractually signed obligations and ensuring the required services. It must also know and observe the content of this Code of Ethics, basing its conduct on respect, cooperation and mutual collaboration.
The foundation pays attention to the facts and listens to people to accept requests and transform them into effective ideas and concrete actions. The comparison with people and territories generates good practices.

3.5. Valuation of Personnel

The Foundation recognizes the centrality of the role of people, recognizing in human resources an indispensable element for the existence, development and pursuit of its mission. Loyalty, preparation and professionalism are fundamental values and conditions for pursuing the growth of the Foundation which, therefore, is committed to contributing to the development of the capacities and competencies of the resources themselves.
The organization and exercise of operational, administrative, accounting and assistance activities are inspired by the principle of legality, as well as by the canons of transparency, good performance and impartiality, and are in accordance with the principles of equal opportunities, of participation in the definition of work objectives, of the enhancement of skills and merit, of optimal use of human, instrumental and material resources, of organizational well-being, of health and safety in the workplace, of the effective distribution of responsibilities.
The Foundation also undertakes to adopt criteria of merit, competence and professionalism for decisions relating to working relationships with the Staff it employs and with Collaborators in general. The Foundation works to ensure that each component, as far as they are competent, adopts behaviors consistent with the above-mentioned criteria and functional to the implementation of these.

3.6. Quality of projects

The Foundation considers it of fundamental importance to carry out its functions according to diligence, competence, professionalism and efficiency.
The Foundation, in carrying out the projects, considers it essential to ensure the quality of the actions carried out and their impact on society.
The innovation of processes, methods and tools aims to disseminate projects widely at national level.

3.7. Risk culture

In carrying out its activities, the Foundation ensures sensitivity to the identification, assessment and treatment of risks, and then to the related control system, in the wider system of governance.
This awareness must be reflected in everyone's concrete behaviors and there must be a widespread perception of how the internal control system actually controls these risks.
The Foundation promotes the dissemination of the culture of control and sensitizes employees and collaborators about the importance of the system of controls and respect, in carrying out institutional activities, current regulations and internal procedures.

3.8. Internal control

The Foundation guarantees that the organization and activities of the internal control officers are carried out in the widest autonomy and in compliance with the principles of confidentiality, independence and fairness, as well as those contained in this Code.
All activities, actions, transactions and operations of the Foundation must be:
• carried out in compliance with current regulations, maximum managerial correctness, the completeness and transparency of the information and both formal and substantive legitimacy;
• carried out in compliance with instructions and procedures and within the limits of the powers received, as well as being legitimate, consistent and appropriate.

Subjects who become aware of any omissions, alterations or falsifications of the accounting records, or of the related supporting documents, are required to promptly inform their superior, or the head of the competent business function.
All information that resides in company computer and telematic systems, including e-mail, must be used exclusively for carrying out business activities, in the manner and within the limits indicated in the company's internal procedures.
The Foundation undertakes to carry out its activities with a sense of responsibility towards the parties involved and the objectives set, to ensure consistency in actions and support for the person. The Foundation undertakes to respect its mission and to carry out the activities provided for by its corporate purpose.

3.9. Conflicts of interest

The Foundation works to avoid situations in which employees and collaborators are or may appear to be in conflict of interest. This situation occurs when a secondary interest, such as economic profit, can influence or expose acts concerning the primary institutional interest to the possibility of influence. The Foundation condemns and prohibits corruption in all its forms, expressly prohibiting all employees and collaborators from engaging in discriminatory behavior aimed at achieving personal interests, contrary to the primary institutional interest.
Any situation or activity that could lead to conflicts of interest or that could interfere with the ability to make impartial decisions must be avoided.

3.10. Protection and confidentiality of data and information

Confidentiality is an essential requirement for carrying out our actions; the Foundation undertakes to protect the confidentiality of all information of any nature or object that it comes into its possession while carrying out its activities, avoiding any misuse or undue dissemination. In accordance with current legislation, the Foundation undertakes to guarantee confidentiality in the processing of data, with special regard to particular data. The adoption of specific procedures to be applied to all areas of one's business meets the need to prevent the use of information outside institutional activity and to pay particular attention to the aspect of computer data management.
The Foundation undertakes to protect, in full compliance with the provisions of Legislative Decree 196/2003 “Code regarding the protection of personal data (Privacy Code)”, and in accordance with GDPR 679/2016 and Legislative Decree 101/2018, the personal data acquired, kept and processed as part of its activity.

3.11. Protection of intellectual property rights

The Foundation, in relation to projects subject to the intellectual property of third parties, undertakes to respect the nature of the project itself, its ownership and its purpose.

3.12. Protection of the environment

The Foundation, in relation to the social activity carried out by the same, promotes an internal policy within the organization attentive to social, environmental and territorial issues.
In line with its line of attention to environmental issues, the Foundation implements the following actions:
• raising the awareness of staff (and all those involved in the Foundation's own activities) aimed at maintaining sustainable behavior from an environmental point of view;
• technological updating of buildings aimed at ensuring, where possible, the reduction of environmental impact.

3.13. Protection of heritage

The Foundation is committed to protecting its assets, in all its components, in order to avoid loss, theft and damage. The assets that are part of the assets can be used only for reasons related to business activity and under no circumstances for illegal activities.

3.14. Anti-money laundering and anti-corruption

The Foundation is committed to full compliance with all applicable anti-money laundering laws, including those that require the reporting of suspicious cash or other transactions.
All financial transactions must, therefore, be adequately justified and must be carried out using means of payment/conferment that guarantee their traceability and legal origin.
The Foundation also adopts measures for the prevention of corruption in accordance with applicable legislation.
The Foundation, in order to prevent the risk of carrying out, even if unintentionally or unwittingly, transactions of any kind involving money, assets or other utilities that are the result of the commission of crimes, abstains from having relationships with subjects based or otherwise operating in countries that do not guarantee corporate transparency and, more generally, from carrying out operations that prevent the reconstruction of the financial flow.
The members of the Foundation are required to:
• verify as far as possible in advance the information available on users, Suppliers and Consultants, in order to assess their reputation and the legitimacy of the activity before establishing any relationship with them that involves obtaining assets or amounts of money for the Foundation;
• to operate in such a way as to avoid any implication in transactions suitable, even potentially, to promote the laundering of money from illegal or criminal activities, acting in full compliance with the primary and secondary anti-money laundering regulations and the internal control procedures prepared for the purpose;
• to comply with current legislation regarding the use and circulation of coins, payment cards, stamps, and any other similar document that enables the withdrawal of cash or the purchase of goods or the provision of services;
• to immediately inform the Competent Judicial Authorities of any transaction that, due to its characteristics, entity and nature, leads us to believe, even taking into account the economic capacity and the activity carried out by the subject to which it relates, that money laundering operations have been carried out or attempted.
The Recipients of this Code are prohibited from engaging in, promoting, collaborating or causing conduct such that, taken individually or collectively, directly or indirectly, the crime of money laundering.

3.15. Gifts and Gifts from Suppliers, Consultants and Third Parties in general

The Foundation, based on its ethical and statutory principles, receives donations from both private entities and legal entities.
The Foundation undertakes to use the donations received for the execution of existing projects and for the values expressed in its statute. Gifts cannot be accepted or received from suppliers, consultants and third parties in general, that is, not in line with normal commercial practice, and in any case such as to jeopardize the integrity or independence of judgment of one of the parties and may be understood as aimed at obtaining advantages improperly.

3.16. Transparency in accounting

Foundation members involved in administrative and accounting activities must scrupulously comply with internal procedures, legal regulations and accounting principles. In particular, accounting records and documents are based on precise and verifiable information and reflect the nature of the transaction to which they refer, they are carefully archived for possible eligibility for verification.
The financial statements and financial statements must provide a true and correct representation of the Foundation's financial, economic and financial position in compliance with current general and special regulations.
Every operation, action and transaction of the Foundation must be properly recorded and documented so as to allow easy traceability and verification of the decision-making, authorization and execution processes.

3.17. Reputation and image of the Foundation

The reputation and image of the Foundation are values to be protected and developed through conduct that complies with laws, this Code and other internal provisions, as well as through the results achieved with respect to the statutory purposes and values of the Foundation.
The Components must refrain from any behavior that could harm the Foundation's image and must also comply with internal provisions on visual identity.

3.18. Fight against terrorism, organized crime and the subversion of the constitutional order

The Foundation requires compliance with all the rules to combat terrorism, organized crime and the subversion of the constitutional order, and undertakes not to enter into any relationship with subjects belonging to associations that pursue these purposes.

3.19. Incompatibility

Should one of the points described above occur, the Foundation reserves the right to interrupt any type of relationship with the parties involved.


4.1. Relationships with Third Parties

In its relations with third parties, the Foundation is inspired by principles of loyalty, fairness, transparency and efficiency. The Members of the Foundation are required to follow correct behavior in matters of interest to the Foundation.
All practices of corruption, fraud, fraud, illegitimate favors, collusive behavior, requests (direct and/or through third parties) for personal and career advantages for oneself or for others are prohibited. The Foundation also undertakes to identify and define specific methods of transparent, documented and traceable management of incoming and outgoing financial resources suitable to prevent the commission of crimes.
In the absence of an express commitment to comply with the rules of the Code of Ethics, the Foundation will not conclude, continue or interrupt its relations with the third party.
Officina Futuro Fondazione W Group implements a policy of sharing and collaboration with partners who share the same goals and objectives as well as the same ethical principles and what is described in this Code.
With regard to partners, Officina Futuro Fondazione W Group welcomes individuals who have skills and reliability, giving priority to those who have goals, purposes and operating methods that are consistent and synergistic with those of the Foundation.
In the case of public partners, the partnership relationship must not affect the work, objectives, purposes and principles of the partner and those of Officina Futuro.
In the case of private and/or profit partners, Officina Futuro has defined that it does not allow receiving donations of materials or financial resources from companies that produce or sell weapons, pornographic materials, promote gambling and anything else harmful and degrading to the human person and the environment and that in any case fail to comply with the Foundation's ethical principles.

4.2. Relationships with Employees and Collaborators

Employees and collaborators must comply with the principles of protection and respect for the human person, loyalty, dignity, morality, fairness in personal relationships, integration and collaboration, sense of responsibility and respect for hierarchical and functional relationships.
The Foundation keeps employees and collaborators constantly informed of the organization's directives through the most appropriate information channels.

4.3. Relationships with suppliers

The Foundation selects suppliers with particular attention in compliance with the principles of transparency, impartiality and fairness, ascertaining effective technical and professional competence and the appropriate means/ tools to deal with the commissioned activity. The Foundation's Staff and Collaborators must not exert any unlawful pressure or request services not contractually foreseen both in terms of content and in terms of methods of execution. In order to adapt the procurement activity to its ethical principles, the The Foundation includes in its contracts with its Suppliers/Consultants the obligation of prior acceptance of the Code of Ethics adopted by the Foundation and provides for specific sanctions or contractual interruptions in the event of a violation of the same. Favoritism, collusive behavior, payment of benefits, material and intangible, or other advantages aimed at influencing the members of the Foundation are absolutely prohibited.

4.4. Relations with Members

The founding partner of the Foundation is represented by W Group and is committed to complying with the ethical principles set out in this Code of Ethics.
W Group pays an annual grant to the Foundation for the execution and achievement of the Foundation's objectives and principles, on an annual basis, or at a differently established frequency.
The Foundation, therefore, undertakes to give evidence to W Group of its work.

4.5. Relations with the Public Administration

The Foundation's relations with the Public Administration and public officials (national and international) are based on full compliance with laws and regulations, while respecting the public nature of the function.
The Foundation establishes that it is forbidden for its members to promise or disburse sums to public officials and employees of the Public Administration in any form directly or indirectly to induce or facilitate the performance of an official act or contrary to the official duties of the Public Administration, carried out to promote the interest/advantage of the Foundation.
Anyone who receives explicit or implicit requests for benefits of any kind from the Public Administration, even under unlawful pressure, must inform the competent Judicial Authority.
The members of the Foundation must not unduly obtain any other type of profit, neither for themselves nor for the Foundation, nor for third parties, to the detriment of the Public Administration, with artifice or deception.
Therefore, the members of the Foundation must under no circumstances:
• make the Foundation obtain, unduly, contributions, loans or other disbursements of the same type provided by the Public Administration, through the use or presentation of false or false documents, or through the omission of necessary information;
• use contributions, grants, and funding intended for the Foundation, for purposes other than those for which they were granted.

4.6. Economic relations with political parties, movements and associations

The Foundation does not make direct or indirect contributions in any form to parties, movements, committees, associations or other bodies of a political or trade union nature or to their representatives and candidates and abstains from any improper pressure against political representatives. The Foundation's participation in electoral campaigns, or in conflicts of any kind, is also excluded.
The Foundation can join requests for contributions from non-profit organizations and associations; any support activities may concern social issues and are intended only for projects that offer a guarantee of the quality of the action with respect to the objective they set themselves. In any case, when choosing the proposals to adhere to, the structure is careful to prevent and avoid any possible conflict of interest of a personal nature or of the structure as such.

4.7. Relations with the Institutions and Authorities competent in the field of supervision and control

The Foundation takes care of relations with public institutions and with the competent authorities in matters of supervision and control, based on the principles of fairness, professionalism and maximum collaboration in full respect of their role, their autonomy and their power of initiative, committing to promptly execute any of their prescriptions. The Foundation's members are required to comply with current legislation in the sectors related to their respective areas of activity and the provisions issued by the competent Institutions and/or Authorities. existing relationships with local, national, European Union and international public institutions or with the competent authorities in the field of supervision and control, requests or requests containing false statements are not submitted, even in order to obtain public disbursements, contributions or subsidized funding, or to unduly obtain unjustified treatment, concessions, authorizations, licenses or other administrative acts. Similarly, in the case of participation in public evidence procedures, the Components of the Foundation those involved are required to operate in full compliance with the law and correct commercial practice, avoiding, in particular, inducing administrations to operate unduly in favor of the Foundation itself. The Recipients are required to verify that public disbursements, contributions or subsidized loans, disbursed in favor of the Institution, are used for carrying out the activities or carrying out the initiatives for which they were granted. The Components of the Foundation comply fully, correctly, adequately and promptly with any request from the competent authorities to carry out checks or controls, providing full cooperation and avoiding obstructive behavior.

4.8. Relations with the Judicial Authority

The Foundation collaborates with the Judicial Authority and with the Bodies delegated by it.
In the event of audits, inspections or investigations, the Foundation's Members are required to make all existing documentation available to the Judicial Authority, without prejudice to the prohibition to destroy or alter records, minutes, accounting records and any other type of document, as well as to make false or reticent statements or to induce others to do so.


5.1. Disclosure of the Code of Ethics

This Code was approved by the Board of Directors on 22 November 2021.
The Foundation informs all Recipients about the provisions and application of the Code of Ethics, recommending compliance with them. In particular, the Company, through the business functions responsible for this purpose, provides:
• the dissemination of the Code of Ethics to the Recipients, through publication on the Foundation's website
• the interpretation and clarification of the provisions contained in the Code of Ethics;
• to verify effective compliance with the Code of Ethics;
• to any future updates and implementation of the provisions of the Code of Ethics, depending on the needs that arise from time to time.
The Code of Ethics is also published, with appropriate relevance, on the officinafuturofondazione.org website.
Any future updates, due to regulatory adjustments or to the evolution of civil sensitivity, will be approved by the Board of Directors and promptly disclosed to all Recipients.

5.2. Implementation of the Code of Ethics within the Foundation and vis-à-vis third parties

All Foundation Members and third-party contractors are required to:
• to review the Code of Ethics and to find out about the related interpretative practices;
• to familiarize yourself with the rules of conduct contained in this Code and emerging from interpretative practices;
• to observe this Code as a standard of ethical appropriateness of the conduct of individuals.
This Code does not replace the precepts contained in laws, regulations and the Statute, but integrates the provisions applicable to the Members of the Foundation and from which they derive rights and obligations.
With regard to Suppliers, Consultants, Managers and Collaborators in general, the Foundation undertakes to include in their respective contracts express termination clauses with reference to the hypothesis of violation of this Code.

5.3. Supervision of the operation and compliance with the Code of Ethics

The task of supervising the operation and compliance with this Code is entrusted to the Board of Directors.
If the Board of Directors detects behavior in violation of the Code of Ethics and identifies the possible responsible party (s), it reports it in writing to the Chairman of the Board of Directors.

5.4. Sanctions

The violation of the rules of the Code may constitute a breach of contractual obligations, with any legal consequence, including with regard to the termination of the contract or assignment and the possible compensation for damages.

5.5. Indignity and decadence

Anyone who has reported a sentence of conviction or application of the sentence at the request of the parties, even if not final, for an intentional crime, cannot be part of the Foundation's central bodies.
No Member of the Foundation who, following a violation of the Code of Ethics, has reported a disciplinary measure, to which a special regulation attributes this effect, can be appointed or elected to the management of administrative and/or welfare structures and/or bodies.

code of ethics